Federal Tax Controversy

Received a Form 5472 Penalty or Facing a Foreign-Owned U.S. Entity Reporting Issue?

Federal tax counsel for Form 5472 penalties, late or incomplete filings, foreign-owned U.S. corporations and LLCs, related-party transactions, and related IRS disputes.

Complimentary Initial Case Screening

Limited to conflicts, matter fit, and potential engagement. Substantive legal advice is provided only after engagement.

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Washington, D.C. Office

800 Connecticut Avenue, N.W.
Suite 300
Washington, D.C. 20006

Direct: +1 202-870-1977

Tysons Office

1750 Tysons Boulevard
Suite 1500
McLean, Virginia 22102

Direct: +1 703-403-1488

Form 5472 disputes commonly involve 25% foreign-owned U.S. corporations, foreign-owned U.S. disregarded entities, foreign corporations engaged in a U.S. trade or business, and reportable transactions with related parties. Chase Counsel evaluates the filing history, ownership structure, related-party transactions, IRS notices and penalty assessments, record-maintenance issues, reasonable-cause defenses, and available administrative or judicial remedies.

Selected matters only. The firm does not provide routine tax-return preparation services.

Attorney Chase Sizemore, JD, LLM

Principal, Chase Counsel PLLC

Georgetown Tax LLM | Former KPMG Auditor

U.S. Tax Court | Columbia University Graduate Studies

National Institute for Trial Advocacy (NITA) Diploma

30+ Years of Legal Experience

When an international information-reporting failure produces an IRS penalty, the issue is no longer tax preparation. It is representation.

What We Handle

Form 5472 Penalty Notices

IRS penalty assessments involving late, incomplete, or disputed Form 5472 filings.

Late or Missed Form 5472

Evaluation of late or missed filings, filing history, corrective options, and potential penalty exposure.

Foreign-Owned U.S. LLCs

Form 5472 matters involving foreign-owned U.S. disregarded entities, including related pro forma Form 1120 filing requirements.

25% Foreign-Owned U.S. Corporations

Reporting and controversy matters involving U.S. corporations with direct or indirect 25% foreign ownership.

Related-Party Transactions

Form 5472 reporting issues involving monetary, nonmonetary, and other reportable transactions with foreign or domestic related parties.

Substantially Incomplete Filings

IRS disputes involving allegations that a Form 5472 was incomplete or failed to satisfy applicable reporting requirements.

Reasonable-Cause Penalty Defense

Fact-specific evaluation and presentation of reasonable-cause defenses in appropriate Form 5472 penalty matters.

IRS Appeals & Penalty Disputes

Administrative challenges, penalty disputes, IRS Appeals matters, and related federal tax controversy proceedings.

Selected matters only. The firm does not provide routine tax-return preparation services.

Request an Initial Case Screening

Before you hire a lawyer, know who you are actually hiring.

Why Clients Choose Chase Counsel

Georgetown Tax LLM | U.S. Tax Court | Former KPMG Auditor | Columbia University Graduate Studies | 30+ Years of Legal Experience

Chase Counsel is not a high-volume tax-resolution practice.

Attorney Chase Sizemore personally evaluates and leads each matter, drawing on more than thirty years of legal and advisory experience. He earned an LLM in Taxation from Georgetown University and previously worked as an auditor at KPMG. He is admitted to practice before the United States Tax Court, completed graduate studies at Columbia University, received advanced trial-advocacy training through the National Institute for Trial Advocacy, and has nearly two decades of professional experience in South Korea and China.

Outside his law practice, he founded and leads Teach Them To Fish Foundation, which builds and supports primary schools in rural Cambodia and Uganda for vulnerable children, with particular emphasis on girls' education. His humanitarian service has been recognized with the U.S. Presidential Lifetime Achievement Award, the Royal Order of Cambodia medal, and eight Cambodian Sthapana Cheat gold medals.

His published and forthcoming work includes the legal treatise Nonprofit Stewards, the memoirs The Road to Kitgum and Where the Red Earth Broke, and numerous legal and scholarly articles.

Speak With Federal Tax Counsel

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Call to discuss your Form 5472 or international tax matter and how we may be able to help.

Call (703) 403-1488

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Reserve a complimentary 30-minute Zoom screening to discuss your Form 5472 or international tax matter and next steps.

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