Late Form 5472 + pro forma 1120 for foreign-owned SMLLC (3 years) + reasonable cause

I am looking for a qualified US tax professional to handle the late filing of Form 5472 + pro forma Form 1120 for a foreign-owned single-member LLC (disregarded entity). I need someone who does this type of work regularly, not a generalist.

1. SITUATION (no confidential details at this stage)

- Single-member LLC formed in a US state in September 2023
- Sole member is a non-US resident individual (based outside the US)
- No US-source income, no US trade or business, no activity beyond basic entity maintenance since formation
- EIN was obtained shortly after formation
- BOIR was filed in early 2025 (before the exemption rule)
- Form 5472 + pro forma Form 1120 has NEVER been filed → 3 tax years are overdue: 2023 (partial year), 2024, and 2025

2. SCOPE OF WORK

- Prepare and file Form 5472 + pro forma Form 1120 for all 3 overdue tax years
- Draft and attach a strong reasonable cause statement for each year to request abatement of the $25,000 per-form penalty
- Submit each package to the IRS (fax or other approved method) and provide me with signed copies + submission proof
- Provide a short memo on going-forward annual compliance so I stay on track

3. QUESTIONS I NEED YOU TO ANSWER IN YOUR PROPOSAL

Please answer ALL of the following in your first message. Proposals that skip these will not be considered.

A. Your professional credentials: Are you a licensed CPA, Enrolled Agent (EA), tax attorney, or another credential? Please state clearly, and mention where you are licensed. If you hold no formal credential, please state that and explain your practical background.

B. Direct experience with this exact type of case: How many Form 5472 late filings for foreign-owned single-member LLCs have you personally handled? How many of those involved a reasonable cause / penalty abatement request? Please give real numbers.

C. Your honest assessment of my case: Based on the facts above (no US activity, no income, voluntary disclosure before any IRS contact), what is your realistic estimate of the probability that the IRS will grant the penalty abatement? Please be honest — I am not looking for false reassurance. If you think it is uncertain, say so.

D. Level of guarantee: Which parts of your service can you guarantee (e.g. filings prepared correctly and submitted on time), and which parts depend on the IRS decision and cannot be guaranteed? Please be fully transparent about what is in your control and what is not.

E. Your proposed approach: In a few lines, how would you build the reasonable cause argument for a case like mine? What are the strongest arguments in the client's favor?

F. Worst-case scenario: If the IRS denies the abatement, what happens next and what are the recommended options?

G. Deliverables: What exactly will I receive when the work is done? (signed forms, submission proofs, memo, etc.)

H. Timeline and fixed price: Total turnaround time and total fixed price for the full package (all 3 years, all deliverables). Please avoid hourly billing.

I. What you need from me: What documents or information will you need to start? I already have: Articles of Organization, EIN letter (CP 575), 147C letter, Statement of Organizer, BOIR confirmation.

4. IMPORTANT

- I will share the company name, EIN, and personal identifying details ONLY after I have selected a professional. Please do not ask for them in your initial proposal.
- I prefer working with someone who has real, verifiable experience with foreign-owned SMLLC late filings. Please do not apply if this is not your area.
- Written, structured proposals with clear answers to questions A–I will be prioritized. Generic copy-paste proposals will be ignored.

Thank you.