In recent months, the IRS has revised a public announcement and issued a practice unit on IRS Form 3520-A reporting and ...

The big reprieve is outlined in IRS Revenue Procedure 2020-17, which exempts from the foreign trust information reporting requirements certain U.S. individuals’ transactions with, and ownership ...

You already know about disclosing a foreign account on your tax return, reporting the income, and separately filing a Treasury Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts ...

On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed ...

See, e.g., PLR 201538008 (superannuation fund treated as foreign trust); PLR 200807003 (same); Rev. Rul. 2008-40, 2008-30 I.R.B. 166 (plan in foreign country maintained to provide retirement ...

IRS defines a Foreign Trust as any trust other than a ... One or more U.S. persons have the authority to control all substantial decisions of the trust. IRS reporting rules apply to a US ...

The U.S. person must file two forms with the IRS to comply with these reporting obligations: IRS Form 3520 to report transfers to and distributions from a foreign trust for the tax year and IRS ...

Specifically, a United States beneficiary who receives a distribution from a foreign trust must file Form 3520 whereas a United States person who is treated as the owner of any portion of a ...

IRS Form 3520, Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts, must be filed by the owner of the trust on the same date as Form 3520-A, when one of ...

Notwithstanding the Proposed Regulations, the reporting requirements for a U.S. person’s involvement with a foreign trust or receipt of foreign gifts or bequests are cumbersome and complex. [1 ...

Last month, the agency held a public hearing on a proposal the IRS released in May that would alter the guidelines for the reporting of transactions involving foreign trusts and gifts reflected on ...