AICPA Makes Useful Recommendations For International Forms 3520/3520

- By : Parag Patel

…Make additional AICPA recommended changes to the Form 3520 and Form 3520-A and instructions,1 including: ▪ Allow e-filing of the Form 3520 and Form 3520-A, which could reduce the number…

Welcome news from IRS for late Form 3520 penalties

- By : Parag Patel

…are settlors/grantors or beneficiaries of foreign trusts may be required to file Form 3520-A and/or Form 3520 to report (1) ownership of the trust, (2) transfers of property to the…

Fantastic Recommendations for Form 3520

- By : Parag Patel

…Internal Revenue Service (IRS) systemic assessment of penalties for late filed Forms 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and 3520-A, Annual…

Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A

- By : Parag Patel

…to provide pension or retirement, medical, disability, or educational benefits are exempt from Forms 3520 and 3520-A reporting. U.S. persons must still file a Foreign Bank Account Report (FBAR), Form…

New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471

- By : Parag Patel

I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471”…

Comments on IRS Form 3520 to Report Foreign Gifts

- By : Parag Patel

3520 (maybe Form 3520-I for inheritance). The most current of Form 3520 pertains to foreign trust reporting, which is entirely irrelevant to a U.S. person filer who seeks to report…

IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A

- By : Parag Patel

…trusts. Taxpayers who would otherwise be required to file Form 3520 and/or Form 3520-A, will not now be required to file these forms if they qualify for the relief set…

Foreign Gifts and the Uncommon Form 3520: A Trap for the Unwary

- By : Parag Patel

…recipient may be required to file Part IV of Form 3520. Form 3520 is the Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts. The…

Forms 3520, 5471 and 5472 Penalty Relief

- By : Parag Patel

…Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) and Form 3520-A (Annual Information Return of Foreign Trust With a U.S. Owner (Under…

New Form 3520 Penalties

- By : Parag Patel

In November 2020, the IRS changed the rules for assessing penalties for Form 3520, the Annual Return to Report Receipt of Foreign Gifts. Form 3520 is filed for any U.S….

Penalties for Not Filing Form 3520

- By : Parag Patel

…a Hearing under IRC 6320. Taxpayers who have incurred penalties for failure to file Form 3520 or late Form 3520 should contact Patel Law Offices. Over the years, our office…

The IRS is Assessing Form 3520 Foreign Information Reporting Penalties

- By : Parag Patel

The IRS is aggressively sending out IRS Notice CP15 “Notice of Penalty Charge” for the late filing of Form 3520 to report the receipt of a foreign gift or foreign…

IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable

- By : Parag Patel

3520, and 3520-A) relating to foreign accounts. The Tax Court largely rejected the taxpayer’s constitutional challenges but did find that the IRS could not automatically assess Form 5471 penalties, a…

What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 3520

- By : Parag Patel

When receiving a penalty for failure to timely file Form 3520, Notice CP 15 or CP 215 is sent to the taxpayer notifying the taxpayer which requires a timely response….

Form 3520 Penalty Relief

- By : Parag Patel

…the late filing of Forms 3520 and 3520-A, which will take somewhat longer to process. If the IRS has assessed penalties, they will be removed, and if a request for…

Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case

- By : Parag Patel

…failed to file Form 3520, or the “Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts,” for $830,000 in cash he received from his mother…

US Reporting of Foreign Retirement Accounts

- By : Parag Patel

…Form 3520 and Form 3520-A is substantial. The penalty for not timely filing a Form 3520 is equal to $10,000 or 35 percent of the gross reportable amount” whichever is…

Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns

- By : Parag Patel

IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and…

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…

From Hong Kong With Love…

- By : Parag Patel

…issue is whether this transfer received is to be reported on a Form 3520? Form 3520 Background: Form 3520 is to be used by “U.S. Recipients of Gifts or Bequests…

Protective Filing of Information Returns

- By : Parag Patel

…is required to file Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) and/or Form 3520-A (Annual Information Return of Foreign Trust With…

Do You Have to Pay US Taxes on Foreign Inheritance?

- By : Parag Patel

…receiving a foreign inheritance: IRS Form 3520 The main form is IRS Form 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts. This form…

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,…

IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)

- By : Parag Patel

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

What is the U.S. tax on Inheritances from a Non-U.S. Person to U.S. Person?

- By : Parag Patel

…receive as a gift from overseas? Unlimited. What IRS tax form do I need to file if I received a gift or inheritance from a foreigner? IRS Form 3520. Although…

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…

IRS gives widespread penalty relief: ACTION REQUIRED

- By : Parag Patel

…1065. Campus assessment program penalties for Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) and Form 3520-A (Annual Information Return of Foreign…

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…