Free tool
Form 5472 penalty calculator.
The IRS assesses $25,000 per Form 5472, per year, automatically, and another $25,000 per 30 days once 90 days pass after a notice.
Use this as a statutory exposure estimate, then compare it with the ordinary catch-up route: file the missing Form 5472 package and include a reasonable-cause statement under DIIRSP.
Initial penalty
1 × 1 × $25,000
$25,000
Total statutory exposure
Based on the counts and notice status entered above.
$25,000
Filing now under the IRS Delinquent International Information Return Submission Procedures (DIIRSP), with a reasonable-cause statement, is the standard resolution path for many late Form 5472 cases. These penalties are frequently abated for first-time late filers who can document reasonable cause, though the IRS decides each case on its facts.
Read the late-filing overview for DIIRSP late-filing steps and the reasonable-cause letter guide for abatement letter requirements.
Statutory exposure under IRC §6038A(d), not a prediction of what the IRS will assess.
How the penalty works
How does the Form 5472 penalty rule work?
The initial penalty applies per Form 5472, per year, and continuation penalties can add more after an IRS notice. We show both pieces together because the calculator is a statutory exposure estimate, not a prediction, and the ordinary next step is still to fix the filing with the missing package and reasonable-cause statement.
What is the initial penalty?
The initial penalty is $25,000 per Form 5472, per year. We use it as a statutory exposure estimate because the IRS assesses it automatically when required Form 5472 information is late, missing, or incomplete, before you compare the number with the ordinary catch-up route.
What happens after a notice?
After an IRS notice, there is a 90-day correction period. If the filing is still not fixed after that window, the statute adds $25,000 for each 30-day period, so we treat the notice timeline separately from the initial per-form, per-year penalty estimate.
What are common triggers?
Common triggers are never filing, filing Form 5472 without the required pro forma Form 1120, or sending an incomplete package. We also flag no-income cases, since a foreign-owned disregarded LLC can still have a filing obligation when reportable transactions include contributions, distributions, and other owner-LLC activity.
What is the relief path?
The relief path is a DIIRSP filing that pairs late information returns with a reasonable-cause statement. We follow the ordinary catch-up route described above: file the missing Form 5472 package, include the statement, and ask the IRS to abate penalties when the facts support reasonable cause.
What are common penalty questions?
Is the Form 5472 penalty really automatic?+
Yes. IRC §6038A(d) provides an initial $25,000 penalty when a reporting corporation fails to furnish required Form 5472 information on time or files an incomplete return.
Can the penalty be abated?+
Yes, but there are no guarantees. Many late filers pursue reasonable-cause relief through DIIRSP, and first-time late filers are frequently successful when the facts support reasonable cause.
What is a CP15 notice?+
A CP15 is an IRS notice assessing a civil penalty. For Form 5472, it is commonly the notice that starts the post-notice timeline for continuation penalties if the filing is still not corrected.
Does having no income exempt me from the penalty?+
No. A foreign-owned disregarded LLC can still have a Form 5472 and pro forma Form 1120 filing obligation even when it had no income, because reportable transactions can include contributions, distributions, and other owner-LLC activity.
Is there a statute of limitations?+
There effectively is not one until a complete or substantially complete return is filed. Read the Form 5472 statute of limitations guide.