News & Analysis as of

Internal Revenue Code (IRC) Tax Penalties Foreign Trusts

Foodman CPAs & Advisors

Forms 3520 and 3520-A Late Filing get IRS Relief

On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more

Gray Reed

IRS Concedes Yet Another Form 3520 Related Penalty Case

Gray Reed on

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations...more

Freeman Law

Failure to Report Foreign Trust Results in 35% Penalty Against the Owner/Beneficiary

Freeman Law on

The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more

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