Seeking U.S. International Tax Attorney for Form 5472 / IRC §6038A Consultation

I am seeking a U.S.-licensed tax attorney with specific experience in Form 5472, IRC §6038A, foreign-owned single-member U.S. LLCs, and international tax penalty/reasonable-cause matters for a focused consultation. I am a non-U.S. owner of a Delaware single-member LLC formed in 2023. The startup has been pre-revenue, but I personally funded X amount of startup expenses from personal international bank accounts and credit cards. Some software-development contracts and NDAs were executed by the LLC, while other expenses—including contractors, business education and travel—were contracted/invoiced personally. Forms 5472/pro-forma 1120 were not filed for 2023–2025 because I was unaware of the requirement. I discovered the issue in May 2026 and immediately began reconstructing the historical records. I need a legal opinion on: Whether the historical owner-funded transactions created Form 5472 filing obligations for 2023–2025. Whether any personally contracted development/IP can legitimately be distinguished from LLC activity and later contributed to the company. Whether filing delinquent Forms 5472/pro-forma 1120 with reasonable-cause statements is the appropriate strategy. How to minimize §6038A penalty exposure while maintaining a legally defensible record for future investor due diligence. Review and advise on the reasonable cause clause. Required experience: U.S.-licensed attorney with demonstrated experience in Form 5472 / §6038A and foreign-owned U.S. entities. Please briefly describe similar Form 5472 matters you have handled and your proposed fee for a 60–90 minute consultation with document review.