Form 3520 Featured Blog Posts
Contents1 Will Form 3520 Fines Become Subject To Deficiency Procedures2 How the Form 3520 Penalty Works3 Unfair and Arbitrary Enforcement4 Challenging Form 3520 Penalties5 Will Farhy and Murkhi Apply to Form 3520?6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance […]
Contents1 Who Must File IRS Form 35202 Who Must File Form 3520 (Individuals)3 What types of transactions must be reported?4 Receipt of Foreign Gifts and Inheritances5 Receipt of Foreign Trust Distributions6 Ownership of a Foreign Trust7 Other Form 3520 Transactions8 Treaty Election or Exception to Substantial […]
Contents1 Did You Inherit Money from Another Country2 Was the Person Giving the Gift a U.S. Person?3 Reporting the Inheritance4 Taxation of the Inheritance5 Pre-Penalty Avoidance 6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure […]
Contents1 Section 643(b) Trusts2 Taxation of a Non-Grantor Trust (NGT)3 What is IRC Section 643?4 Understanding the Formation of an NGICDST5 What does a ‘Spendthrift Provision’ in a Trust Mean?6 How is the NGICDST Trust Funded?7 How is the NGICDST Income Taxed?8 Golding & Golding: About […]
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 Late Filing Penalties May be Reduced or […]