Form 5472 penalty exposure — foreign-owned US LLC

Late Forms 5472 x 25,000 each (IRC 6038A), 30-day add-ons after an IRS notice, and your April 15 / October 15 due date

First tax year with a reportable transaction (owner funding, fees paid) year Latest tax year to check year Foreign related parties (one Form 5472 each per year) Form 7004 extension for the latest year? Check as of (YYYY-MM-DD) IRS notice date, if you got one (YYYY-MM-DD, else blank) Forms named in that notice

Late Forms 5472	—
Initial penalties (25,000 each)	—
30-day periods after notice + 90 days	—
Continuation penalties	—
Total penalty exposure	—
Latest due date	—
Days late / left	—
What this means	—

Full version: .csv export of this year-by-year penalty schedule for your CPA + a browser reminder before every April 15 / October 15 due date. $60 once · one licence key per person or team seat.

Late form count
Counts one Form 5472 per foreign related party per tax year whose due date has passed: tax years 2023, 2024 and 2025 with no extension filed = 3 late forms on 2026-09-23.

25,000 per form
Multiplies each late form by the IRC 6038A(d) penalty of 25,000: 3 late forms = $75,000 total exposure, with no maximum.

30-day add-on after a notice
Adds 25,000 per form for each 30-day period (or part) that runs more than 90 days after the IRS mails a notice.

April 15 or October 15
Shows the due date of the latest tax year: 2026-04-15 without Form 7004 (161 days late on 2026-09-23), 2026-10-15 with Form 7004 (22 days left).

.csv schedule and reminders (key)
With a licence key: export the year-by-year schedule as .csv for your CPA and get a browser reminder before each due date.

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