Notice 2022 – 36 provides penalty relief for 2019 & 2020 where tax returns that were filed on or before September 30, 2022.
Single member LLC would've had to file its Form 1120, with the associated Form 5472, on or before September 30, 2022, to obtain this relief.
However, in the attached FL–2022–19, the IRS provides victims of hurricane IAN until February 15, 2023 to file returns for deadlines falling on or after September 23, 2022 and before February 15, 2023.
So, it appears that taxpayers now have until February 15, 2023 to file their 2019 & 2020 late filed Form 1120, with the associated Form 5472, for single member LLC is owned by a foreigner to obtain penalty waiver relief pursuant to Notice 2022–36.
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