By Caroline Rule
The CPA Journal
December 2017 Edition
Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is frequently unclear, yet penalties for a failure to file can be severe. As a result, although there is no formal procedure for filing a protective Form 3520, practitioners should consider doing so when there is any uncertainty about whether a taxpayer must file the form.
