Did the IRS really stop charging Form 3520 penalties in late 2024? Is it safe to file late now?
I owe a couple of late Form 3520 filings — one for a foreign gift, one for a trust year. My feed keeps surfacing posts saying the IRS ended automatic 3520 penalties at the end of 2024 and that late filers with a good explanation no longer get hit. That sounds too good to be true. What exactly changed, and what does a reasonable-cause explanation have to contain for this to work?
Related Questions
Two years behind on Forms 3520 and 3520-A after immigrating — what order do I fix things in?
Classic mess: I funded a foreign trust before moving to the US, became a resident two years ago, and have filed regular income tax returns ever since — but never a 3520 or 3520-A. There have also been...
My mother sent $75,000 and my aunt $40,000 in the same year — each under $100,000, so no Form 3520, right?
I became a US resident last year. This year my mother (not a US person) wired me $75,000 and her sister added another $40,000, both to help me settle in and fund my company. Neither transfer crosses t...
New US resident, just received a large distribution from my family's foreign trust — how is it reported and taxed?
In my first year as a US tax resident, my parents' foreign trust (they funded it, not me) distributed about $300,000 to me to help buy a home. I assumed this was just a family gift. A CPA friend said ...
What do Form 3520 and 3520-A penalties actually look like in dollars? Trying to size my exposure
I'm reconstructing several years of foreign trust filings I didn't know I owed — I moved to the US three years ago with a family trust in the background. Before I talk to a professional I want to unde...
Is my foreign employer pension really a foreign trust that needs Form 3520? I just moved to the US
I relocated to the US this year for my startup. Back home I have an employer-sponsored retirement plan and a government-encouraged savings account, both built up over a decade of salary deferrals. My ...
I never filed Form 3520 for old trust transfers — hasn't the three-year audit window closed by now?
Years ago, after I had already become a US person, I contributed to a foreign trust and never filed Form 3520 — honestly, I didn't know the form existed. Those tax years are now more than three years ...
I funded a foreign family trust in 2023 and become a US resident in 2026 — is there really a deemed transfer on day one?
Three years ago, while I was still a nonresident, I moved shares of my company into a foreign family trust for succession planning. Next year I'm relocating to the US for good. A cross-border advisor ...
US owner of a foreign grantor trust with zero transactions this year — do I still file Form 3520 and 3520-A?
After moving to the US, I'm treated as the owner of my foreign trust under the grantor rules. This year the trust did absolutely nothing — no contributions, no distributions, no asset sales. My foreig...
Does the $18,000 annual gift tax exclusion apply to non-resident aliens?
I'm a non-resident alien living in Brazil and I want to give money to my niece who lives in the U.S. for her education. Can I use the annual gift tax exclusion? Is it the same $18,000 amount as for U....
Are my late mother's U.S. bank deposits automatically in the U.S. taxable estate just because the bank is in America?
My mother was a nonresident and not a U.S. citizen, but she kept money in U.S. financial accounts for convenience. We are now sorting out whether those accounts belong in the U.S.-situs gross estate o...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
