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IRS notices · checked 24 October 2026

IRS CP215 notice: what it means and how to respond

A CP215 is the IRS's "Notice of Penalty Charge": it tells a business that a civil penalty has been charged to its account. For foreign-owned US LLCs, the most common reason is a late or missing Form 5472, which carries a $25,000 penalty.

First, read what the penalty is for

The notice names the penalty, the tax period and the amount, and gives a date to respond by. Interest can build from the notice date if it isn't resolved, so don't put it in a drawer.

If it's a Form 5472 penalty

  1. Make sure the form is filed. If it's still missing, file the late Form 5472 with its pro forma Form 1120 now. Filing a missed Form 5472.
  2. Reply in writing before the date on the notice, asking for the penalty to be removed for reasonable cause. Explain what happened, why it wasn't wilful neglect, and what you've done to fix it, with proof the form has now been filed.
  3. Use the small-corporation point if it fits. In 2026 IRS guidance (CCA 202617012) the IRS said reasonable cause should be applied liberally for small corporations that didn't know about the rule, had limited US presence and cooperated promptly. Penalty relief and the letter.
  4. If it's refused, the refusal letter explains how to go to the IRS Independent Office of Appeals.
  5. If you already paid it, Form 843 is the usual way to ask for it back.

Keep copies of everything

The notice, your reply, fax confirmations or mail receipts, and the late return. If the IRS doesn't answer, call the number on the notice and quote the date you replied.

When to get a professional

If several years are involved, the penalty has already been refused once, or the LLC had real US income, a US tax professional who handles international information returns is worth paying for.

Check what else my company owes

Related: Form 5472 deadlines · official Form 5472 PDF · faxing it from abroad.

Sources: H&R Block, "IRS Notice CP215: Notice of Penalty Charge" (a civil penalty has been charged; interest from the notice date); IRS Chief Counsel Advice CCA 202617012 (reasonable cause for small corporations), as summarised on our penalty relief page. Read 24 October 2026. General information, not tax advice.