Tax Law Center Blog

I was a principal author on behalf of the American Bar Association in preparing 60+ pages of comments submitted to the Internal Revenue Service (IRS) on proposed regulations concerning foreign trust transactions and recipients of significant gifts from foreign individuals. I used the opportunity to comment on foreign trust and gift reporting regs and asked the IRS to reform its penalty procedures in an area rife with controversy.

We responded to a request by the IRS for comments on proposed regulations for Transactions with Foreign Trusts and Information Reporting on Transactions with Foreign Trusts and Large Foreign Gifts (REG-124850-08). Since posting the proposed regulation for commentary, the IRS has received over 1000 submissions, including people assessed large Form 3520 penalties and expats who may find that their foreign pension plans qualify for reporting as a Foreign Trust (form 3520/3520A).

A copy of our comprehensive comments can be found here.