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Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary

- By : Parag Patel

…at the close of the taxable year. (iv) The failure to timely file a complete and correct Form 3520 or Form 3520-A may result in an additional penalty of $10,000…

Protective Filing of Information Returns

- By : Parag Patel

…additional information returns (Forms 3520 and/or 3520A) to report a foreign trust? A U.S. person with an ownership interest in a foreign corporation may need to file an information return,…

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

- By : Parag Patel

…U.S. law, and may have failed to file an FBAR (FinCEN Form 114, previously Form TD F 90-22.1) and/or one or more international information returns (e.g., Forms 3520, 3520-A, 5471,…

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

- By : Parag Patel

…Foreign Corporation • Form 3520, Annual Return to Report Transactions with Foreign Trusts & Receipt of Foreign Gifts • Form 3520-A, Annual Information Return of Foreign Trust With a U.S….

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…(Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) by e-mailing the CIS ID number to “*LB&I OVDP Compliance” with an explanation that the case is being forwarded due to…

Beware of Overlooked Common Overseas Tax Forms

- By : Parag Patel

…trust, you are likely required to file Form 3520-A in addition to form 3520. If you run your own business in a foreign country, you may have established a company…

Full Analysis of Updated 2012 OVDP Program

- By : Parag Patel

…contacts the taxpayer requesting the delinquent returns or regarding an examination. In FAQ 18, the Service states that a taxpayer who has failed to file Form 5471 or Form 3520,…

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

- By : Parag Patel

…file delinquent or amended tax returns, together with all required information returns (e.g., Forms 3520, 5471, and 8938) and (2) for each of the most recent 6 years for which…

Details of the Delinquent International Information Return Submission Procedures (DIIRSP)

- By : Parag Patel

…information returns. It applies to all the following international-related information returns: • Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation • Form 3520, Annual Return…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) for the foreign financial asset; and (4) these failures resulted from non-willful conduct. To be eligible for the streamlined…

More Tax Complexity: New Form 8938

- By : Parag Patel

…on Form 3520, Form 3520-A, Form 5471, Form 8621, Form 8865, or Form 8891, you do not need to report the asset on Form 8938. On the Form 8938, however,…

Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities

- By : Parag Patel

…Specified Foreign Financial Assets Foreign Trusts Reporting Forms Form 3520-A Annual Information Return of Foreign Trust With a U.S. Owner Form 3520 Annual Return to Report Transactions With Foreign Trusts…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

…date) has passed together with any required information returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) even if these information returns would normally not be submitted had…

The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

- By : Parag Patel

…Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund), among others. IRS Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…information returns (e.g. Form 3520 or 5471), for the past three years and to file delinquent FBARs (Form TD F 90-22.1) for the past six years. Payment for the tax…

The legal standard of “willfulness”: Opt out to avoid high penalties

- By : Parag Patel

…the Taxpayer was a grantor of, or transferor to a foreign trust (which requires filing Form 3520).   A willful failure to file a FBAR can lead to a felony…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…aggregate have more than 50% of the partnership, you may need to file this form to report income and transactions between you and the partnership. Form 3520: Annual Return to…

New Extended Deadline for OVDI

- By : Parag Patel

…Information Return of U.S. Persons With Respect To Certain Foreign Corporations, and Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, where all…

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

…income for prior years but did not file FBARs or other information returns related to reporting foreign income and/or assets (e.g., Form 3520 and Form 5471) can file their delinquent…

IRS Releases FAQs for the Delinquent International Information Return Submission Procedures

- By : Parag Patel

…penalty for the failure to file the delinquent Forms 5471 and 3520 if there are no under-reported tax liabilities and you have not previously been contacted regarding an income tax…

Frequent Scenarios in Offshore Voluntary Disclosures

- By : Parag Patel

…bequest a Report of Foreign Gift or Bequest (Form 3520) may also need to be filed. Whether the U.S person has dominion or control over the account is determined by…

The IRS is Hiring: Expect New Enforcement

- By : Parag Patel

…will be more audits with respect to Forms 5471 (owners of a foreign corporation), 3520/3520A (owners and beneficiaries of foreign trusts), 8621 (PFICs, including foreign mutual funds) and 8865 (owners…