Form 3520 Voluntary Disclosure
Form 3520 Voluntary Disclosure: While technically, there is no specific voluntary disclosure program exclusively for form 3520, the IRS 3520 Form is often a common part of a voluntary disclosure submission. Whether it is because a U.S. Person received a gift from a foreign person, an inheritance from a foreign person, or has ownership over a foreign trust (or received a distribution from a foreign trust) – the form 3520 can be a complicated endeavor.
What makes the form less known than other international information reporting forms, is that many times the person who is required to file the form 3520 may not have had any other tax filing requirement (e.g., may not meet the threshold for having to file a U.S. tax return).
In the all too common situation, a U.S. adult child may have received a gift from a foreign parent, but never reported the gift to the IRS.
What is Form 3520 Voluntary Disclosure?
Voluntary disclosure is an alternative to the 3520 reasonable cause submission.
Generally, when a person is non-willful and the only issue they have is a form 3520, they will qualify for Form 3520 Reasonable Cause.
*When a person meets the reasonable cause requirements, they may qualify for a complete penalty waiver.
IRS Form 3520 Voluntary Disclosure Options
When a person refers to voluntary disclosure, they are generally referring to the full-scope of different offshore tax amnesty options and not specifically the Voluntary Disclosure Program (aka Post-OVDP). When it comes to voluntary disclosure in general, there are various different options depending on a persons facts and circumstances.
When a person is willful, they are limited to the traditional voluntary disclosure program.
But, when a person is non-willful they may qualify for either the streamline procedures and international delinquency procedures.
*Sometimes a person may be able to use voluntary disclosure to completely avoid any penalties for the noncompliance with filing form 3520.
Considering Form 3520 Voluntary Disclosure?
Our firm specializes exclusively in international tax, and specifically IRS offshore disclosure, including help clients with late reporting of Forms 3520 and 3520-A.
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.
Each case is led by a Board-Certified Tax Law Specialist with 20-years experience, and the entire matter (tax and legal) is handled by our team, in-house.
*Please beware of copycat tax and law firms misleading the public about their credentials and experience.
Less than 1% of Tax Attorneys Nationwide Are Certified Specialists
Our lead attorney is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.
Recent Case Highlights
- We represented a client in an 8-figure disclosure that spanned 7 countries.
- We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
- We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
- We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
- We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.
How to Hire Experienced Offshore Counsel?
Generally, experienced attorneys in this field will have the following credentials/experience:
- 20-years experience as a practicing attorney
- Extensive litigation, high-stakes audit and trial experience
- Board Certified Tax Law Specialist credential
- Master’s of Tax Law (LL.M.)
- Dually Licensed as an EA (Enrolled Agent) or CPA
Interested in Learning More about our Firm?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant.
We specialize in FBAR and FATCA. Contact our firm today for assistance with getting compliant.