Form 3520 Featured Blog Posts
Contents1 Gifts from Foreign Persons 2 The Purpose of Form 35203 Form 3520 Foreign Gift4 Form 3520 Foreign Inheritance5 Form 3520 Trust Distribution6 Form 3520/3520-A Ownership of Foreign Trust7 Related Persons8 Trust Reporting Exceptions (2020-17 and Proposed Regulations)9 The Tip of the Iceberg10 Late Filing Penalties May […]
Contents1 The IRS Announces Excellent Changes to Late Form 3520 Rules2 First, Why Are Form 3520 Penalties a Problem?3 What Will the IRS Change About the Late Form 3520 Filing Rules?4 Initial Thoughts on What Lies Ahead5 Late Filing Penalties May be Reduced or Avoided6 Current […]
Contents1 What is a CP15 Notice for Form 3520?2 Why Did Taxpayer Receive a Form 3520 Penalty?3 30-Days to Show Reasonable Cause4 Did The Taxpayer Already Submit a Reasonable Cause Statement with Form 3520?5 Was Taxpayer’s Reasonable Cause Statement Even Considered?6 Should Taxpayers Appeal the CP15 […]
Contents1 Form 3520 Penalty2 Why Did Taxpayer Receive a Form 3520 Penalty?3 30-Days to Show Reasonable Cause4 Did The Taxpayer Already Submit a Reasonable Cause Statement with Form 3520?5 Was Taxpayer’s Reasonable Cause Statement Even Considered?6 Should Taxpayers Appeal the CP15 Form 3520 Penalty?7 What […]
Contents1 5 Facts About Form 35202 More than $100K Gift includes Related Parties?3 Form 3520 is Not Limited to Just Cash Gifts4 Did the Taxpayer Receive a Foreign Trust Distribution?5 Automatically Assessed Penalties are Common6 Taxpayers Can Challenge the Form 3520 Penalty7 Late Filing Form 3520-A […]
Contents1 Form 3520 Penalty Explained2 First, a Gift vs Loan3 Individual Large Foreign Gift Example4 Entity Large Foreign Gift Example5 Multiple Gifts Example6 Large Foreign Inheritance7 Foreign Trust Distribution8 Foreign Trust Ownership9 Defenses to Late-Filed IRS Form 3520 Penalties10 What is Reasonable Cause?11 Information Return Penalty […]
Contents1 Do I have to Talk to an IRS Agent for Failing to File Form 3520?2 VDP (Voluntary Disclosure Program)3 Streamlined and Delinquency Procedures4 Examinations, Audits, and the IRS Special Agents5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 […]
Contents1 Form 3520-A Filing Requirements & Reporting Rules2 First, The IRS Does Not Like Foreign Trusts3 When is Form 3520-A Due?4 Can You Apply for an Extension?5 Appointing a U.S. Agent and Form 3520-A6 Foreign Grantor Trust Owner Statements7 Foreign Grantor Trust Beneficiary Statements8 Foreign Pension […]
Contents1 Proposed Foreign Gift and Trust Regulations 2 $100,000 Gift to Adjust for COLA3 Additional Information About the Transferor4 Dual-Status Definition of a U.S. Person5 Migration of Foreign Trust to Domestic is a Distribution6 Limited U.S. Agent Status to Avoid Harsh Tax Consequences7 Late Filing Penalties […]
Contents1 Form 3520-A Filing Requirements & Reporting Rules2 What Is Considered to Be A Foreign Trust?3 U.S. Trust with Foreign Assets4 When is a Foreign Trust Taxable?5 Foreign Grantor and Non-Grantor Trust Beneficiary Statement6 When is a Foreign Trust Reportable?7 Does the Foreign Trust Qualify For […]
Contents1 Is a Malta Pension Plan Reported as a Trust 2 What is the Malta Pension Plan (MRS)?3 Why is it Reported as a Foreign Trust?4 Form 3520/3520-A Reporting5 Malta Retirement Scheme Fines and Penalties6 Form 3520-A Penalties7 Form 3520 Penalties8 Late Filing Penalties May be Reduced […]
Contents1 Who Reports Foreign Inheritance to the IRS?2 David is a Visa Holder3 David Applied for LPR so No CCE4 David Received a Foreign Inheritance5 David Must Still File Form 35206 Penalties and Abatement7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs Prior […]
Contents1 Will Form 3520 Fines Become Subject To Deficiency Procedures2 How the Form 3520 Penalty Works3 Unfair and Arbitrary Enforcement4 Challenging Form 3520 Penalties5 Will Farhy and Murkhi Apply to Form 3520?6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance […]
Contents1 What is IRS Form 3520?2 Section 6039F3 Notice 97–34, Page 24 Section 60485 What is Form 3520?6 Who Must File Form 3520?7 What is Reported on Form 35208 When is Form 3520 Due?9 Can You Apply for an Extension for Form 3520?10 What if You […]
Contents1 Did You Inherit Money from Another Country2 Was the Person Giving the Gift a U.S. Person?3 Reporting the Inheritance4 Taxation of the Inheritance5 Pre-Penalty Avoidance 6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure […]
Contents1 Section 643(b) Trusts2 Taxation of a Non-Grantor Trust (NGT)3 What is IRC Section 643?4 Understanding the Formation of an NGICDST5 What does a ‘Spendthrift Provision’ in a Trust Mean?6 How is the NGICDST Trust Funded?7 How is the NGICDST Income Taxed?8 Golding & Golding: About […]
Contents1 Foreign Trust Reporting and Taxes2 What Is Considered to Be A Foreign Trust?3 U.S. Trust with Foreign Assets4 When is a Foreign Trust Taxable?5 Foreign Grantor and Non-Grantor Trust Beneficiary Statement6 When is a Foreign Trust Reportable?7 Does the Foreign Trust Qualify For Any Exceptions […]
Contents1 Definition of Foreign Trust Created by a U.S. Person2 1.643(d)-1 Definition of Foreign Trust Created by a United States Person3 Summarizing the Foreign Trust Definition4 Foreign Trust Examples5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs Prior Year Non-Compliance 7 Avoid False […]
Contents1 Is my Foreign Legal Structure a Trust?2 Entity Classification – Fairbank (2023)3 Elements of a Foreign Trust4 Is it Really a Foreign Trust?5 US vs Foreign Trust6 Toth Case (2022)7 Federal Tax Law Controls 8 Classification Under US Tax Law9 Not Always A Trust10 A […]
Contents1 Who Has a Form 3520/3520-A Filing Obligation?2 Gift from a Non-Resident Alien Individual3 Inheritance from Non-Resident Alien Individual4 Gift from a Foreign Entity5 Gifts from Foreign Related Persons6 Foreign Trust Distributions7 Ownership of a Foreign Trust8 Form 3520/3520-A Penalties9 Late Filing Penalties May be Reduced […]