How late can I be before DIIRSP no longer works?

There's no hard deadline — DIIRSP is available until the IRS contacts you about the specific delinquency. Once a CP-15 arrives, you must use a different appeal process.

Is there a chance the IRS just won't notice?

Unlikely. The IRS automated system cross-references EIN holders, and foreign-owned DEs are a known compliance focus area since 2018.

Can I file under DIIRSP myself?

Yes. The procedure is publicly documented. The hardest part is writing a strong Reasonable Cause Statement — our service generates one for you.

Form 5472 + 1120 filing service

Filed Form 5472 Late? Here's What to Do Now

If you missed the April 15 deadline for Form 5472, file as soon as possible. The IRS Delinquent International Information Return Submission Procedure (DIIRSP) lets you submit late filings with a Reasonable Cause Statement requesting that the $25,000 penalty be waived. The longer you wait, the higher the risk of an automatic CP-15 penalty notice.

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What happens if you do nothing

Within 6-18 months of the missed deadline, the IRS automated system issues a CP-15 notice assessing the $25,000 penalty. Once that notice arrives, your options narrow: • You can pay it • You can appeal it (much harder than filing under DIIRSP preemptively) • You can ignore it — but then the IRS starts collection action against the LLC's US assets, and continuation penalties accrue at $25,000 per 30-day period

What to do right now

1. Don't panic. The IRS has not yet assessed the penalty if you haven't received a CP-15 notice. 2. Prepare the late return immediately. Each missed year requires its own Form 5472 + pro forma 1120. 3. Write a Reasonable Cause Statement (or use our service to generate one). 4. File via DIIRSP — mail or fax to the IRS Ogden PIN Unit. 5. Keep the fax confirmation as proof of timely DIIRSP filing.

What if you've missed multiple years

File ALL missed years in one DIIRSP package. Don't space them out. The IRS treats a comprehensive catch-up filing more favorably than serial late filings. Our multi-year DIIRSP packages handle the common cases: • 2-year catch-up: $89 + $19 fax • 3-year catch-up: $129 + $19 fax The reasonable cause statement covers all years with one consistent narrative.

What if you've already received a CP-15 notice

DIIRSP is no longer available for that specific year. You need to: 1. Respond to the CP-15 within 30 days 2. Submit a Form 843 (Claim for Refund and Request for Abatement) with a strong reasonable cause explanation 3. Consider hiring a CPA or tax attorney for the appeal We currently don't handle CP-15 appeals — only preventative DIIRSP filings. If you have a CP-15 notice, talk to a US tax professional.

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We generate every form, you sign one PDF, we fax it to the IRS Ogden PIN Unit. Flat $49.00 + $19.00 fax delivery.

Filled IRS Form 5472 + pro forma 1120
Reasonable cause statement (if late)
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Frequently asked questions

How late can I be before DIIRSP no longer works?: There's no hard deadline — DIIRSP is available until the IRS contacts you about the specific delinquency. Once a CP-15 arrives, you must use a different appeal process.
Is there a chance the IRS just won't notice?: Unlikely. The IRS automated system cross-references EIN holders, and foreign-owned DEs are a known compliance focus area since 2018.
Can I file under DIIRSP myself?: Yes. The procedure is publicly documented. The hardest part is writing a strong Reasonable Cause Statement — our service generates one for you.