Search Results for: 3520
Beware of Overlooked Common Overseas Tax Forms
…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…
New IRS IRM with Updated Streamlined Filing Compliance procedures
…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…
Solution: Streamlined Domestic Offshore Procedures
…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…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…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…
Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities
…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…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…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…
More Tax Complexity: New Form 8938
…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,…
Do Inherited Foreign Assets Receive a Step-up in Cost Basis for U.S. Tax Purposes?
…foreign inheritance on IRS Form 3520 in the year it was received. This form can be an important strategic document for claiming a future cost-basis when the asset is eventually…
Checklist of tax forms for taxpayers with foreign assets
…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…
The legal standard of “willfulness”: Opt out to avoid high penalties
…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…
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…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
…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…
Rare confluence of tax law and immigration law
…applicant must affirmatively state that he or she does not owe any taxes and has filed all required returns, including FBARs, and other international forms such Forms 8938, 3520, 8621,…
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
…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…
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
…assess and collect Form 5471 penalties. It is also possible that other penalties for failure to file certain international information returns (e.g., Form 3520 for reporting gifts received from foreign…
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
…returns for the most recent three years for which the due date has already passed. At the same time, the taxpayer must file any associated informational returns, including Forms 3520,…
Frequent Scenarios in Offshore Voluntary Disclosures
…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…
Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)
…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…
New Extended Deadline for OVDI
…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…
The IRS is Hiring: Expect New Enforcement
…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…