You received a Form 5472 penalty notice
This path isn't self-checkout. A CPA reads your facts first, then tells you whether we can take the case and what it costs. Fill this in and you'll hear back within one business day.
Does First-Time Abate apply to Form 5472?
Generally, no. The IRS's standard First-Time Abate relief does not cover Form 5472, because it's an event-based filing requirement rather than a recurring return. Relief runs through reasonable cause under Treas. Reg. §1.6038A-1 instead. Anyone telling you a clean filing history alone will clear it is wrong.
If you own a small foreign-owned company, "I didn't know" may count for more than you think
A Chief Counsel memo released in April 2026 (CCA 202617012) discusses a reasonable cause standard for small corporations — broadly, $20 million or less in gross receipts, limited presence in and contact with the United States, no knowledge of the section 6038A rules, and prompt compliance once contacted.
The memo is nonprecedential and it is not automatic relief. But it describes the situation most of our clients are in, and it belongs in the analysis.