Foreign Trust and Gift Reporting: Recent Developments | CPE Course

BarbriSFCourseDetails

Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
Intermediate
work Practice Area
Tax Preparer

Date & Time

event Date
Tuesday, February 11, 2025
schedule Time
1:00 p.m. ET./10:00 a.m. PT
timer Program Length
110 minutes

Credit Information

BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00

CPE

ALL

This webinar will provide an overview of the legislative history affecting taxpayers with foreign trusts and receiving certain foreign gifts. Our panel of international tax advisers will review the recent proposed regulations, discuss Form 3520 and 3520A reporting requirements, and provide practical advice for applying these rules and avoiding penalties.

Faculty

C. Edward Kennedy

Managing Director

C Edward Kennedy Jr, PC

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

Alex McGowin

International Tax Accountant

McGowin Tax, LLC

Mr. McGowin is a trusted advisor to multinational individuals and businesses seeking to optimize their global tax position and stay in compliance.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

Description

IRC Section 6048 contains strict reporting requirements to address concerns that U.S. taxpayers avoid taxation by implementing foreign trusts. Satisfying these requirements includes reporting certain transactions on Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Historically, the IRS has assessed steep systematic reporting penalties for failure to report these transactions.

In May 2024, the IRS and Treasury released proposed regulations covering foreign gift and trust transactions. As is often the case, the release has generated questions on the application of these guidelines. The newly released regulations are similar to the rules in Notice 97-34 for reporting foreign gifts. They outline the requirements to establish foreign residency to avoid U.S. reporting requirements. Tax practitioners and taxpayers with dual residency status, foreign retirement plans, or receiving gifts from outside the U.S. must grasp the implications of recent guidelines impacting certain foreign transactions.

Listen as our panel of foreign gift reporting experts explains recent legislative developments impacting foreign trust and gift reporting.

Outline

Recent developments in foreign trust and gift reporting
Form 3520 and 3520A reporting requirements
Foreign retirement plans
Legislative history
1. Notice 97-34
2. Revenue Procedures 2014-55
3. Revenue Procedure 2020-17
4. Proposed regulations (REG-124850-08)
5. Other guidelines
IRS enforcement campaign
Applicable penalties
Practical implications

Benefits

The panel will cover these and other critical issues:

Comparing Revenue Procedure 2020-17 and the newly proposed regulations
The current state of IRS enforcement of reporting requirements under IRC Section 6048
Reporting guidelines for reporting foreign retirement plans
The legislative history surrounding reporting foreign trust and gift transactions

NASBA Details

Learning Objectives

After completing this course, you will be able to:

Identify recent developments in foreign trust and gift reporting
Determine the legislative history of reporting foreign retirement and gift transactions
Decide how Form 3520 is used to satisfy the reporting requirements under IRC Section 6048
Ascertain key differences between Rev Proc 2020-17 and the May 2024 proposed regulations for reporting foreign trust and gifts

Field of Study: Taxes
Level of Knowledge: Intermediate
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.