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 back, so I assumed the IRS can no longer audit them and the cleanest move is to stay quiet. A new advisor told me the limitations period never started for those years. How can that be?
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