Several Years of Form 5472 Late: One Catch-Up, Start to Finish
Summary
Every open year gets its own Form 5472 and pro forma Form 1120, oldest first, all sent together under one reasonable cause statement. Filing only the latest year invites a question about the rest.
Kemal lives in Istanbul and builds mobile games. He formed a Wyoming LLC in September 2022 so an app store could pay a US company. In July 2026, a payment platform's compliance review asked for the LLC's US tax filings. He had none, and found that one had been due every April since 2023.
This is how his catch-up was put together. The steps are the same for any owner with more than one open year and simple facts.
Step 1: list every year the LLC existed
The LLC's first tax year began on the day it was formed. Kemal's open years:
| Tax year | Covers | Was due |
|---|---|---|
| 2022 | September 14 to December 31, 2022 | April 15, 2023 |
| 2023 | Full year | April 15, 2024 |
| 2024 | Full year | April 15, 2025 |
| 2025 | Full year | April 15, 2026 |
The 2026 year is not late yet: it is due April 15, 2027, and gets filed on time in the normal way.
Step 2: find each year's transactions with the owner
Form 5472 reports transactions between the LLC and its foreign related parties, which for Kemal means himself. Working from the bank statements, year by year:
- 2022: he paid the formation fee and the first registered agent fee personally, and moved $2,000 in to open the account.
- 2023: the LLC paid him $18,000 across four transfers.
- 2024: he lent the LLC $5,000 in March to cover an advertising push, and it paid him $24,000 later in the year, including the $5,000 back.
- 2025: the LLC paid him $31,000.
App store payouts to the LLC are not on any of these lists. The app store is not a related party. The reportable transactions page explains where that line falls.
Every year had at least one transaction, so every year needs a return. A year with genuinely nothing between the LLC and its owner may not, and if one comes up, keep a note of why it was left out.
Step 3: one packet per year, in order
Each year gets its own complete set: a Form 5472 for that year's transactions, attached to a pro forma Form 1120 with "Foreign-owned U.S. DE" across the top and only the LLC's name and address and items B and E completed. Four years, four sets. Years are never combined onto one form.
They go in order, oldest first, so the reader at the IRS sees the history in sequence.
Step 4: one statement that covers all four years
Kemal's statement tells one story, because it was one failure: the LLC was formed through an online service that described state obligations and never mentioned an IRS return; he has no US adviser; nothing in his professional life in Turkey involves US information returns; and he learned of the requirement from the payment platform in July 2026 and filed every year within weeks.
That last fact carries the most weight. Reasonable cause under IRC §6664(c) is measured partly by what an owner did once they knew, which is why all four years go in at once. Sending 2025 now and the rest later would leave a gap in the story that the statement cannot explain. The penalty abatement letter page covers what the statement must contain.
Step 5: send it, and keep everything
The whole packet goes to the IRS PIN Unit at 1973 Rulon White Blvd, M/S 6112, Ogden, UT 84201, or by fax to 855-887-7737. It cannot be e-filed. Kemal used a courier that records delivery, and kept a full copy of every page with the delivery record.
Why every year, and not just the recent ones
Filing only 2025 is the tempting shortcut, and it goes wrong three ways:
- Old years stay open. Under IRC §6501(c)(8), the assessment period for a year does not begin until that year's Form 5472 is filed. 2022 is as open as 2025.
- The gap is visible. A first-ever return from an LLC formed in 2022 invites the question of where 2022 to 2024 went.
- The reasonable cause story breaks. Knowing about the requirement and filing only part of it is hard to present as ordinary business care.
What is at stake if nothing is done is set out on the $25,000 penalty page: the amount is per form and per year, so four open years with one related party each carry four times the exposure of one.
When the simple route is not enough
Kemal's case was simple: one owner, ordinary payments, no US business income, and no IRS letter. A catch-up needs a qualified CPA review before anything is sent if the IRS has already written about any of the years, if other foreign companies or relatives dealt with the LLC, or if the LLC earned income from a US trade or business.
For simple cases like his, FileTax prepares every open year's Form 5472 and pro forma Form 1120 as one job at $99 per year, and one CPA-authored reasonable cause letter covering all of the years for $199. Filing past years shows how the job is laid out.
Questions about catching up several years
How far back do I go?
To the year the LLC was formed, including a first part-year. Every year with a reportable transaction needs a return, however old.
Do I need a separate reasonable cause statement for each year?
No. One statement covering the whole period is stronger, because the failure had one cause. It should name every year it covers.
What if one of the years had no transactions?
That year may not need a return. Keep a short record of why, such as the bank statements for that year, in case the question comes up later.
Does filing all the years at once reduce the penalty?
No. The maximum stays the same. What filing together does is make the case for not assessing it, because it shows prompt, complete action once you knew.
The IRS has written about one of the years. Does this still apply?
For the year on the notice, the route changes to filing the return and requesting abatement on Form 843, and the other open years should go in at the same time. The missed Form 5472 page sorts out which situation you are in.
Related pages
Continue reading
Missed Form 5472? Four Situations, and the Relief Path for Each →
File voluntarily with a reasonable cause statement before the IRS writes; answer with Form 843 after it does. Complex facts need a CPA review first, whichever side of a notice you are on.
Form 5472 Penalty Abatement Letter: What It Must Contain →
A Form 5472 penalty abatement letter is a written reasonable cause statement asking the IRS to remove the $25,000 late-filing penalty. What it has to contain, and how it is filed.
Reportable Transactions on Form 5472: 18 Common Ones, Yes or No →
Funding the LLC, paying its fees yourself, loans and distributions are all reportable. Customer payments, suppliers and moving money between the LLC's own accounts are not.