Wealth Management: The IRS Provides Good News for Certain American Expats

Is your client an American who has lived or worked outside the United States and owns foreign trusts? Has he paid a penalty for late filed Form 3520 or 3520A for 2016, 2017, 2018 or paid an earlier year penalty within the last 2 years?

If so, there may be good news. This week the Internal Revenue Service issued new guidance in Revenue Procedure 2020-17 (the guidance) that may exempt qualifying U.S. citizens and residents with foreign trusts from the onerous reporting requirements. This means that they may not have to file the Form 3520, due April 15, and Form 3520A, due March 16 going forward if they qualify.

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