For people living abroad, those who once worked in the United States, or anyone with foreign assets or companies, the IRS requires certain “international information forms.”
These are not tax forms but reporting forms, and many people don’t even know they exist.
Because the forms are complicated and unfamiliar, many taxpayers skip them accidentally.
You might think:
“I didn’t know I had to file this!”
“I found out years later that I should’ve filed a form…”
For people in this situation, the IRS created the
Delinquent International Information Returns Submission Procedures (DIIRSP).
This blog explains DIIRSP in simple, everyday language so people with no tax background can understand it easily.
DIIRSP stands for Delinquent International Information Returns Submission Procedures.
In plain terms, it means:
These international information forms include documents required when you:
Own shares in a foreign corporation
Receive money or gifts from foreign individuals
Have foreign assets such as bank accounts or investments
Are involved with a foreign trust
Own part of a foreign partnership
The most common forms affected are:
Required if you are a U.S. person who owns or has control over a foreign corporation.
Contents include:
Basic corporate information
Balance sheets
Income statements
Shareholder information
Transactions between you and the foreign corporation
$10,000 per form, per year
If still not filed after IRS notice:
$10,000 per 30 days (maximum additional $50,000)
Required when a corporation (including an LLC) has 25% or more foreign ownership, or a U.S. entity has certain transactions with a foreign related party.
Contents include:
List of related foreign owners
Details of any money exchanged with foreign parties
Transactions such as loans, services, or purchases
$25,000 per form, per year
Additional $25,000 if not corrected after IRS notice
Form 3520 reports:
Foreign gifts over certain thresholds
Foreign inheritances
Transfers to foreign trusts
Form 3520-A reports:
Income and operations of a foreign trust
Beneficiary information
For foreign gifts: 5% of the gift per month, up to 25%
For foreign trusts: Penalties can start at $10,000 and go much higher depending on the situation
Reports:
Foreign bank accounts
Foreign stocks
Foreign partnerships
Foreign pensions
Cryptocurrency (in some cases)
$10,000, increasing up to $50,000 with continued failure
The biggest advantage of DIIRSP is simple:
Since these forms carry heavy penalties—sometimes $10,000 to $25,000 per form per year (it varies) —the financial impact can be huge.
Under DIIRSP, you can file the forms late without penalties, as long as:
Your failure was non-willful, AND
You don’t owe additional tax from the missed reporting
DIIRSP is specifically for cases where:
You forgot or did not know the forms were required.
Not everyone can use this procedure.
You can use DIIRSP if:
If the IRS is already reviewing your case, DIIRSP cannot be used.
Meaning:
You didn’t know about the requirement
You misunderstood the rules
You forgot unintentionally
This non-willful concept does not equal to your reason that you did not know the rules. The tax concept today is wider and more objective.DIIRSP is only for informational forms, not when your tax return itself was wrong.
If taxes were underpaid, another program is used, such as the Streamlined Filing Compliance Procedures.
The process is generally straightforward:
This may include multiple years of Form 5471, 5472, 3520, 8938, etc.
This is a letter explaining:
Why you filed late
How you discovered the requirement
What you did to correct it
The IRS does not require fancy legal wording—just an honest explanation.
Once submitted, the IRS reviews it.
If they accept it, no penalties will be assessed.
DIIRSP is helpful for people who:
Recently learned about Form 5471 or 8938
Own foreign corporations without realizing reporting was required
Received foreign gifts or inheritances
Have foreign bank accounts
Expatriates or immigrants to the U.S.
People married to U.S. citizens
Anyone with international financial connections
Many ordinary individuals qualify because the rules are extremely complex and easy to miss.
International reporting forms can be confusing and overwhelming.
Even experienced accountants sometimes misunderstand the rules.
The DIIRSP program helps people who:
Filed late by accident
Didn’t know they needed to report something
Want to fix the issue before the IRS contacts them
It is one of the most important compliance programs for anyone with international ties. Please consult with a professional firm like CHI Border.
This blog is for general informational purposes only and does not provide legal, tax, or financial advice.
Every individual’s situation is unique, and tax outcomes vary.
For proper guidance, consult a qualified U.S. tax professional familiar with international taxation (such as a CPA or tax attorney).
This information should not be used as a substitute for personalized professional advice.