Form 3520 Featured Blog Posts
Contents1 Foreign Trust Reporting and Taxes2 What Is Considered to Be A Foreign Trust?3 U.S. Trust with Foreign Assets4 When is a Foreign Trust Taxable?5 Foreign Grantor and Non-Grantor Trust Beneficiary Statement6 When is a Foreign Trust Reportable?7 Does the Foreign Trust Qualify For Any Exceptions […]
Contents1 Definition of Foreign Trust Created by a U.S. Person2 1.643(d)-1 Definition of Foreign Trust Created by a United States Person3 Summarizing the Foreign Trust Definition4 Foreign Trust Examples5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs Prior Year Non-Compliance 7 Avoid False […]
Contents1 Is my Foreign Legal Structure a Trust?2 Entity Classification – Fairbank (2023)3 Elements of a Foreign Trust4 Is it Really a Foreign Trust?5 US vs Foreign Trust6 Toth Case (2022)7 Federal Tax Law Controls 8 Classification Under US Tax Law9 Not Always A Trust10 A […]
Contents1 Who Has a Form 3520/3520-A Filing Obligation?2 Gift from a Non-Resident Alien Individual3 Inheritance from Non-Resident Alien Individual4 Gift from a Foreign Entity5 Gifts from Foreign Related Persons6 Foreign Trust Distributions7 Ownership of a Foreign Trust8 Form 3520/3520-A Penalties9 Late Filing Penalties May be Reduced […]
Contents1 What is the Definition of a Beneficiary for Trust?2 679(a) Transferor treated as Owner3 1.679-2 Trusts treated as having a U.S. beneficiary.4 Beneficiaries of a Foreign Trust Examples5 Current Year vs Prior Year Non-Compliance6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Golding & Golding: […]
Contents1 Is a Foreign Inheritance Taxable 2 Estate vs Inheritance Tax (Federal Level)3 Taxation vs Reporting4 NRA (Non-Resident Alien) vs US Person Living Abroad5 Are the Assets Located in the US or Abroad? 6 Do the Inherited Assets Generate Income?7 Current Year vs Prior Year Non-Compliance8 Avoid […]
Contents1 How are Distributions from Foreign Trusts Taxed2 Worldwide Income3 Foreign Trust without US Assets4 Grantor Trust (US Person Owner)5 Non-Grantor Trust (US Person Beneficiary)6 Throwback Rule7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Need Help Finding an […]
Contents1 Form 35202 What is Form 3520?3 Tax Return Requirement4 Who Has to File Form 3520?5 When Is Form 3520 Due?6 Where Is Form 3520 Filed?7 What Is the Threshold for Gifts From Foreign Individuals?8 Threshold for Foreign Gifts From Foreign Entities9 Threshold For Distributions from […]
Contents1 Foreign Grantor Trust Tax Rules 2 Foreign Grantor Trust Taxation3 IRC 6714 Examples from IRC 1.671-25 Current Year vs Prior Year Non-Compliance6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Golding & Golding: About Our International Tax Law Firm Foreign Grantor Trust Tax Rules With the […]
Contents1 Failure-to-File Penalty for Foreign Trust Penalties 2 Revenue 2020-17 or 2014-55 & Failure-to-File Penalty3 5 Key Facts About Form 3520-A Penalty4 Preemptive Reasonable Cause Not Willful Neglect5 Form 3520-A Abatement (Protest Letter)6 Appealing Form 3520-A Failure-to-File Penalty7 Collection Due Process Hearing8 Tax Court or Federal […]