FORM 3520

[HOPE2]

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!

[sjrcpa]

From today's IRS e-News for Tax Professionals:

The Department of Treasury and the IRS released proposed regulations for transactions with foreign trusts, as well as information reporting on transactions with foreign trusts and large foreign gifts that are reported using Forms 3520 and 3520-A. Recent feedback from stakeholders has highlighted potential opportunities for improvement with respect to the IRS’s penalty processes related to Forms 3520 and 3520-A. As such, the IRS has assembled a working group to further evaluate its penalty processes associated with Forms 3520 and 3520-A to identify opportunities for improvement, reduce burden and incentivize voluntary compliance. We plan to have further details on the group’s recommendations soon.