Hi,

The new client forgot to file Form 3520 for 2022 timely. After reviewing the Form 3520 instructions, I did not find common reasons for failing to file the form that would provide relief from penalties. She received a gift of $101000 from her non-resident father. Additionally, she did not have any foreign accounts that would require filing FBAR or Form 8938.

Any insight or guidance would be greatly appreciated!