How to catch up on missed Form 5472 filings (DIIRSP)

DIIRSP — pronounced like "deersp" if you say it out loud, which nobody does — stands for the Delinquent International Information Return Submission Procedure. It's the IRS's catch-up program for people who should have been filing certain international forms (including Form 5472) and weren't.

It's not an amnesty program in the legal sense. There's no application, no approval process, no waiting period. You just file the missing returns the normal way, attach a short letter explaining why you're late, and submit. If the IRS finds the explanation reasonable, no penalty is assessed.

This guide walks through the whole thing end-to-end.

Step 1: Confirm DIIRSP is the right path for you

You qualify if:

• You owe one or more international information returns (Form 5472, Form 5471, Form 8938, etc.) for years where they weren't filed.
• You have not already received an IRS notice or audit letter about the missing returns.
• You have not been previously contacted by the IRS about an examination of your taxes.
• You can articulate a reasonable explanation for why the filings were late.

If any of those don't apply, DIIRSP isn't the right procedure — you'd need to request penalty abatement through the standard process instead, which is decided case-by-case.

Step 2: Gather the years

Figure out exactly which tax years you missed. For a calendar-year LLC, the form is due April 15 (or October 15 with extension) of the year after the tax year. So:

• The 2024 tax year was due April 15, 2025
• The 2023 tax year was due April 15, 2024
• The 2022 tax year was due April 15, 2023
• ...and so on

You need to file every missed year, not just the most recent. The IRS treats them as separate obligations. If you skip a year in your catch-up, that year stays open forever.

For each year, collect:

• Capital contributions you made to the LLC (money in)
• Distributions you took out (money out)
• Any other transactions between you and the LLC (loans, expense reimbursements, etc.)
• Year-end total assets (close enough — for a no-revenue LLC this is usually $0 or a small balance)

If you don't have records, your bank statements are usually enough. The IRS isn't looking for forensic accounting — they want to see that you've made a good-faith effort to report what moved.

Step 3: Prepare one package per year

Each missed year gets its own Form 5472 + pro forma Form 1120 package. You don't combine years into a single filing. So if you're catching up 3 years, you're preparing 3 complete packages.

Each package contains:

1. A pro forma Form 1120 — most fields are blank for a disregarded LLC. Name, address, EIN, the relevant tax year on top, and the income/deduction lines all zeroed out (or filled with actual figures if your LLC had US activity).
2. A Form 5472 attached to it — Part I (the reporting entity), Part II (the foreign owner), Part III (more on the owner), Part IV (reportable transactions), and any other parts that apply to your situation.
3. For the late years specifically: the reasonable-cause statement (covered in Step 4) attached to the front.

Step 4: Write the reasonable-cause statement

One statement covers all the late years — you don't need to write one per year. It should be on its own page, no special formatting, addressed to the IRS, and signed by you.

A good statement covers:

• Who you are: name, country of residence, the LLC's name and EIN.
• What the LLC does: a sentence on the business. If it's dormant or had no US activity, say that.
• Why the filings were late: the honest reason. "I wasn't aware of the Form 5472 requirement," "I relied on my formation agent who didn't mention it," "My country has no equivalent reporting and the obligation didn't surface in my research."
• What you've done since: "Upon learning of the requirement, I'm now filing for all missed years and going forward."

Half a page is enough. Keep it factual, not apologetic. The IRS reviewer sees hundreds of these — clarity beats eloquence.

Step 5: Submit by fax or paper mail

Foreign-owned disregarded LLCs cannot e-file Form 5472. Your two options are:

• Fax to the IRS Ogden PIN Unit at +1-855-887-7737. This is the recommended route — you get a transmission receipt as proof of filing, and processing time is faster.
• Paper mail to: Internal Revenue Service, 1973 Rulon White Blvd., M/S 6112, Attn: PIN Unit, Ogden, UT 84201. Send certified with return receipt.

All years go in the same fax (or the same envelope), with the reasonable-cause statement on top, followed by the earliest year's package, then the next year, and so on.

Step 6: Wait, and verify

The IRS doesn't send a confirmation letter when DIIRSP filings are accepted — silence means it worked. If you don't hear anything for 90 days, you're likely fine.

If the IRS does send a notice (rare for clean DIIRSP filings), it'll usually either request more information or assess a penalty despite the reasonable-cause request. In either case, respond promptly with additional explanation — most cases get resolved without penalty even at this stage.

Common questions

How many years can I catch up at once?

No limit. People routinely catch up 5+ years through DIIRSP. The earlier years are no harder to file than recent ones.

Do I need to amend any other returns?

Usually no. For foreign-owned single-member LLCs with no US source income, the LLC is disregarded for US tax — there's no separate corporate return to amend. The Form 5472 catch-up is typically the entire fix.

Should I hire a CPA?

For a straightforward foreign-owned LLC catch-up, probably not. CPAs charge $300–$800 per year of catch-up for what is essentially form-filling. A specialised service does it for ~$69–$149 per year. The form is the same regardless of who prepares it.

What if the LLC is dormant or had zero activity?

You still file. Form 5472 reports reportable transactions, which include the capital contributions you made to set up the LLC. Zero revenue is not zero filing. A dormant LLC gets a filing that says "we set this up, nothing moved through it, here's the year-end balance of basically nothing." It's still required.

If you'd rather not assemble the packages yourself, that's what we built Snapfile for — answer 12 questions, get a complete catch-up package per year, signed and faxed for you, at $89 for the current year and $69 per extra past year.