Federal · Internal Revenue Service
International information return penalties
CP15 · CP215 (Forms 5471, 5472, 3520, 3520-A, 8938, 8865)
- What it is
- Fixed-dollar penalties for a late, incomplete or missing international information return, assessed systemically when the form arrives late with the return. Reasonable cause is the main defense, and the standard is applied strictly.
- The clock it starts
- Pay or respond by the date on the notice; a reasonable-cause request is made in writing with the response, and the penalty can be appealed after the request is denied.
- What a response has to establish
- A reasonable-cause statement that meets the manual's elements: the facts of the failure, the taxpayer's compliance history, and the steps taken once the failure was discovered.
- Authority
- IRC §6038
- IRC §6038A
- IRC §6038D
- IRC §6677
- IRM 20.1.9
What CitedTax drafts for this notice
A reasonable-cause abatement letter for the specific form and section, following the IRM 20.1.9 procedure.
One credit. Upload the notice, state the firm's position and the facts, and the draft comes back in about thirty minutes with every claim graded against the cited text.
Other federal notices
For tax professionals. The date printed on the notice controls. CitedTax is a research and drafting tool; the reviewing professional validates every item before reliance.