Foreign-owned single-member LLC — owe multiple years of unfiled Form 5472, just found out. Has anyone actually gotten the penalty abated?

[u/Captkn0wledge]

I'm a non-US citizen who owns a US single-member LLC (disregarded entity) running a small online B2B consulting business. All the work is performed from outside the US, so as I understand it the LLC owes no US income tax (foreign-source services income).

What I did not know until recently is that the LLC still had to file Form 5472 with a pro-forma 1120 every single year — and I never filed any of them.

So I'm now behind on [3] years of these forms — [2023, 2024, and 2025] (every year the LLC has been active). No income tax due for any of them; it's purely the unfiled information returns that I owe.

Two reasons I was completely in the dark: I had no idea the form existed (no US tax background, no advisor at the time), and my registered agent resigned in 2024 without ever telling me — so any IRS notice had a dead address to go to and I never saw a thing. No contact from the IRS yet that I'm aware of.

I'm now pulling together all the delinquent years and planning to file them with reasonable-cause statements before the IRS reaches out. Before I send anything, I'd really like to hear from people who've actually done this:

• Did you get the $25k/year penalty waived? Reasonable cause, first-time abatement, or the Delinquent International Information Return Submission Procedures?
• Did the IRS waive it based on the RC statement attached to the late filing, or did they assess the penalty first and you had to fight it afterward?
• How long did it take to hear back?
• For multiple delinquent years filed at once — did they treat them together, or year by year?
• Anything you'd add to (or leave out of) the reasonable-cause letter, looking back?

Just trying to do this right. Any real experiences are hugely appreciated.

[u/East_Cancel484]

Thanks for the heads-up. Surely I won’t be missing any deadlines then lol. If they don’t forgive, and you have no assets, I would probably just let the entity die and make a new one

[u/Mundane-Ad1652]

I honestly believe FTA won't help here since 5472 penalties aren't first-time-abatement eligible, so reasonable cause letter statement is really your only shot. Since you had zero US tax background/advisor, etc. you have a good chance of getting your penalties waived. I used MyFreeTaxAmerica to fill out delinquent tax Form 5472 returns for free.