• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abatements for Delinquencies

$347.00

This course is $0 with these passes:

CLE
ALL
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About the Course

Introduction

This CLE/CPE course will provide tax counsel with a comprehensive and practical guide to a deep exploration into the 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.

Description

Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is one of the most complex tax reporting forms in the IRS international tax reporting regime. Taxpayers who own an interest in a foreign-based trust or receive gifts, inheritances, or distributions from a foreign source are required to report these foreign "reportable events," even if the taxpayer does not receive income from these foreign sources.

A significant challenge for taxpayers is determining whether a taxpayer qualifies as a "responsible party" for purposes of filing Form 3520. As in most U.S. tax reporting of foreign activities, extremely steep penalties apply for failure to correctly and timely file Form 3520, including a base penalty of 35% of the value of the reportable event. While Section 6677 provides for reasonable cause relief, the provisions to claim that relief are complex and burdensome for taxpayers and tax counsel alike.

Tax counsel and advisers need to have a thorough understanding of the regime for reporting foreign-based trusts, including claiming relief from penalties for failure to file or incorrect filing of Form 3520. Tax advisers can help their clients avoid costly penalties by navigating foreign trust reporting rules.

Listen as our experienced panel provides a deep dive into the filing requirements and specific sections of Form 3520, along with a discussion of penalties and relief provisions, to help you keep clients with foreign trust holdings compliant with IRS rules.

Presented By

Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, October 13, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Determining owners and responsible parties

II. Reportable events

A. Obligations

B. Gratuitous transfers

C. Qualified obligations

D. Distributions and calculations

E. Gifts and bequests

F. Other form items

III. IRC Section 6677 penalties for failure to file and relief provisions

A. Calculation of penalties

B. Section 6048 special rules

C. Reasonable cause exception

IV. Form 3520 reporting and schedule preparation

The panel will review 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?
  • What are the filing requirements for the U.S. beneficiary of a foreign non-grantor trust?
  • What are the penalties and relief provisions for failing to file a Form 3520 or Form 3520-A?
  • What are the processes for establishing a reasonable cause exception for penalty abatement?
  • Are there statutory defenses to the 3520 and 3520-A Penalty Regime?