Form 3520 Foreign Trust Reporting for Tax Counsel: Navigating Filing Requirements and Penalty Abatements for Delinquencies
Establishing Reasonable Cause Exceptions, Appeals Prior to Payment, Collection Due Process and More
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a comprehensive and practical guide to a deep exploration into reporting regime for U.S. taxpayers’ ownership of foreign trust assets on IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. The panel will detail the events and transactions that require reporting, and discuss tax counsel’s role in remedying an absent or incorrect filing, including navigating the penalty abatement process for failure to correctly and timely file a Form 3520.
- Determining “owners” and “responsible parties”
- Reportable events
- Gratuitous transfers
- Qualified obligations
- Distributions and calculations
- Gifts and bequests
- Other form items
- IRC Section 6677 penalties for failure to file and relief provisions
- Calculation of penalties
- Section 6048 special rules
- Reasonable cause exception
The panel will discuss these and other key issues:
- What “reportable events” trigger a Form 3520 filing requirement?
- What is the overlap between Form 3520 and other foreign information reporting requirements, such as Forms 5471, 8865, 8621 and Schedule B?
- What are the filing requirements for the U.S. beneficiary of a foreign non-grantor trust?
- What are the penalties, and relief provisions, for failure to file a Form 3520 or Form 3520-A?
- What are the processes for establishing a reasonable cause exception for penalty abatement?
Alison N. Dougherty, J.D., LL.M.
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.Close
Richard S. LeVine
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held... | Read More
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held companies and other high-net-worth U.S. and foreign individuals. He counsels clients on pre-immigration and pre-expatriation tax planning, offshore trusts and foundations deferred compensation planning for fund manager and structures involving life insurance. He has been heavily involved in advising clients on the IRS Voluntary Disclosure programs.Close
Aaron T. Kriss
Mr. Kriss assists corporations, partnerships, investment managers and entrepreneurs in structuring their business... | Read More
Mr. Kriss assists corporations, partnerships, investment managers and entrepreneurs in structuring their business enterprises in a tax-efficient manner. He has extensive experience in the manufacturing, financial services, investment management, real estate and high-tech industries, and advises clients on large-scale transactions involving both U.S. and international income tax planning. He presents on an array of tax and international tax issues.Close