Note that assets reported on timely filed Forms 3520
, 5741, 8621, and 8865 (see above for all) do not have to be reported on Form 8938.
This case involved the penalties for failing to file Forms 3520
(12) As a corollary, the OVDP Frequently Asked Questions and Answers (FAQs) provided that if a taxpayer qualifies for and makes a Question 17 Submission, then no penalties would be assessed for the late filing of informational returns, such as Forms 3520
The penalty is effective for Forms 3520
flied after Dec.
The Statistics of Income (SOI) study of 2006 foreign trust information returns (Forms 3520
and 3520-A) is consistent with substantial and increasing interest in foreign investment by U.S.
Foreign trusts that are not business entities must now file Forms 3520
The tax form, in Part IV, "Excepted Specified Foreign Financial Assets," has a line to indicate the "Number of Forms 3520
" filed for the corresponding tax year.
For delinquent informational returns, the taxpayer must submit the information return with an amended return (except Forms 3520
and 3520-A, which are exempt from this requirement) and a statement that establishes reasonable cause for failing to tile such returns.
The majority of Forms 3520
filed reported trust transactions or trust ownership, although the percentage of Forms 3520
related to gift or bequest transactions was significant (Figure C).
There is no requirement to report this interest on Forms 3520
, 3520-A, or 8891.
The 1998 foreign trust statistics, reported on Forms 3520
and 3520-A, show the substantial growth of foreign investment by U.S.
The delinquent information forms, except for Forms 3520
and 3520-A (which are filed separately according to the instructions for those forms), should be attached to an amended return filed in accordance with the amended return's instructions.