• videocam Live Webinar with Live Q&A
  • calendar_month December 17, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparation - Trusts and Estates
  • schedule 110 minutes

IRS Challenges to Foreign Gifts: Forms 3520 and 3520-A

Reasonable Cause Relief, Recent Litigation, and Responding to IRS Assessments

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About the Course

Introduction

This CPE webinar will address the IRS' evolving enforcement of penalties related to the filing of Forms 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts, and 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner. Our panel of astute international tax advisers will review recent procedural changes to the IRS' penalty regime, notable case law addressing the receipt of foreign gifts, and best responses to IRS penalty assessments in specific scenarios.

Description

Under Section 6677, the IRS may assess a penalty for incomplete, inaccurate, or delinquent Forms 3520 and 3520-A. The penalty equals the greater of $10,000, 35% of the gross value of property transferred to or distributed from a foreign trust, or five percent of the gross value of a foreign trust's assets owned by a U.S. person under the grantor trust rules. An additional $10,000 penalty applies for each 30-day period a failure continues beyond 90 days after IRS notification.

The IRS announced in late 2024 that it would begin reviewing reasonable cause statements before assessing certain penalties associated with late-filed Forms 3520 and 3520-A, replacing the prior practice of automatic assessment in many cases. At the same time, courts continue to wrestle with the scope of reasonable cause relief and procedural challenges to penalties imposed for foreign gift reporting failures. Recent cases, including Huang v. United States, have highlighted how reasonable cause relief applies and strategies for seeking penalty abatement. 

Listen as our panel of international tax controversy professionals examines recent IRS enforcement initiatives, litigation involving Forms 3520 and 3520-A, and best practices for preventing, challenging, and resolving foreign gift and foreign trust reporting penalties.

Presented By

Matthew L. Roberts
Partner
Meadows Collier

Mr. Roberts is a tax litigator and trusted advisor with significant experience in counseling both domestic and international clients in civil and criminal tax liability matters. He routinely handles IRS and government examinations and investigations, administrative appeals, collection, and litigation proceedings. Mr. Roberts also advises clients on complex tax planning matters including issues related to the taxation of settlements and judgments, theft losses, and other tax losses. He has served as counsel of record in over one hundred United States Tax Court cases, representing clients in controversies ranging from $100,000 to $100 million. Mr. Roberts routinely represents high-net-worth individuals, entrepreneurs, non-profits, fiduciaries of trusts and estates, partnerships, and corporations in varied industries including oil and gas, financial services, and real estate. He manages tax compliance and reporting matters—such as voluntary disclosures to address unfiled or incorrect returns—and advises on international tax reporting and penalties (e.g. IRS Forms 3520, 5471, and FBAR). Mr. Roberts also advises taxpayers on complex tax reporting positions.

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Beatrice Skyberg
Director of International Business Development Tax
Alliance Trust Company of Nevada

Ms. Skyberg has more than 14 years of public accounting experience providing services to a variety of clients. She specializes in international and domestic fiduciary, gift and estate taxation and provides corporate, partnership and individual taxation services. Ms. Skyberg assists with compliance, consulting and planning services for a variety of nonprofit organizations and private foundations.

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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).

Date + Time

  • event

    Thursday, December 17, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. IRS challenges to foreign gifts received: introduction

II. IRS enforcement of foreign gift and foreign trust reporting requirements

III. Pursuing reasonable cause relief

IV. Recent notable cases

V. Responding to IRS penalty notices

VI. Best practices and strategies

The panel will review these and other critical issues:

  • Calculating penalties imposed under IRC Section 6677
  • The IRS' shift to pre-assessment review of reasonable cause statements
  • Notable recent cases challenging IRS assessment of penalties for inadequate or non-filing of Forms 3520 and 3520-A
  • Appropriate responses to assessment of penalties for non-filing Forms 3520 and 3520-A
  • The current state of the IRS' compliance campaign targeting receipt of foreign gifts


Learning Objectives

After completing this course, you will be able to:

  • Identify reporting obligations and penalty exposure associated with Forms 3520 and 3520-A
  • Determine how recent IRS administrative changes affect penalty assessments and reasonable cause requests
  • Decide how best to respond to IRS penalty notices for not filing Form 3520
  • Ascertain when litigation is a viable alternative to penalties assessed for not reporting foreign gifts received 
  • 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 estate, gift and trust taxation including various trusts types, the unified credit, and portability.

BARBRI, 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.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .