Form 3520-A (Annual Information Return of Foreign Trust With a U.S. Owner) is the FOREIGN TRUST's annual return under IRC §6048(b) when any US person is treated as the OWNER of any portion of the trust under the grantor trust rules of §§671-679. CRITICAL DISTINCTION: Form 3520-A is filed BY the foreign trust (not the US owner); Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) is filed by the US person reporting transactions, ownership, and large foreign gifts. Both must be filed annually if the trust is a foreign grantor trust with US owner. Form 3520-A INCLUDES THREE STATEMENTS: (1) Foreign Grantor Trust Owner Statement (pages 3-4 of the form) provided to each US owner so the owner can report the trust's income on their own Form 1040; (2) Foreign Grantor Trust Beneficiary Statement (page 5) provided to each US beneficiary receiving distributions; (3) the foreign trust must furnish these statements to US owners and US beneficiaries. KEY FILING DATES: Form 3520-A due by the 15th day of the 3rd MONTH after the end of the trust's tax year (March 15 for calendar-year trust). Form 7004 grants 6-month automatic extension to September 15. SUBSTITUTE FORM 3520-A: If the foreign trustee FAILS to file timely, the US owner must complete a "substitute Form 3520-A" to the best of their ability and attach it to their own Form 3520 by the Form 3520 due date - this is one of the most commonly missed compliance steps. §679 - US person treated as owner if transfers assets to a foreign trust with a US beneficiary; HIRE Act 2010 §533 expanded - uncompensated use of trust property by US person treated as distribution under §643(i); HIRE Act loan rule §643(i) - loans of cash or marketable securities to US person at non-market interest treated as distribution. PENALTIES §6677 - greater of $10,000 OR 5% of trust's gross value attributable to US owner's portion for failure to file Form 3520-A; greater of $10,000 OR 35% of contribution/distribution for failure to file Form 3520. EXCEPTIONS via Rev. Proc. 2014-55 - Canadian RRSPs and RRIFs exempt; Rev. Proc. 2020-17 - certain "tax-favored foreign trusts" (foreign retirement/savings, medical, disability, educational benefits) exempt for eligible individuals if specific requirements met. T.D. 10037 (January 2025) and proposed regulations under §6048 expand exemption framework. T.D. 10024 January 2025 added related-party basis-adjustment transactions to required disclosure.
Who files: The FOREIGN TRUST files Form 3520-A (the US owner does NOT file it directly; the US owner files Form 3520 separately). Required when a US person is treated as the owner of any portion of the foreign trust under §§671-679 grantor trust rules.
When: 15th day of 3rd month after trust's tax year-end (March 15 for calendar-year). 6-month automatic extension via Form 7004 using the FOREIGN TRUST's EIN (not the US owner's SSN). For calendar-year 2025, due March 15, 2026; with extension September 15, 2026.
What's included: Full accounting of trust activities + Foreign Grantor Trust Owner Statement (to US owner) + Foreign Grantor Trust Beneficiary Statement (to US beneficiaries receiving distributions).
Substitute Form 3520-A: If foreign trustee fails to file timely, US owner completes substitute to best ability and attaches to their Form 3520 by Form 3520 due date - PROTECTS the US owner from §6677 penalties despite trustee's failure.
Penalty §6677: Greater of $10,000 OR 5% of gross value of trust attributable to US owner's portion. Even one missing form can mean $20,000+ penalty notice.
Exemptions: Canadian RRSPs/RRIFs (Rev. Proc. 2014-55); certain tax-favored foreign retirement/savings trusts (Rev. Proc. 2020-17); these exemptions do NOT affect FBAR or Form 8938 reporting.
| Filing Trigger | Detail |
|---|---|
| Statutory authority | IRC §6048(b); Notice 97-34; Reg §1.6048-2 (proposed) and existing regulations |
| Foreign trust definition §7701(a)(31)(B) | Any trust that is NOT a US person (does not meet court test AND control test of Reg §301.7701-7) |
| US owner trigger | US person treated as owner of any portion of foreign trust under grantor trust rules §§671-679 (excluding §678 for purposes of §6048) |
| §679 specific trigger | US person transfers property (directly or indirectly) to foreign trust which has, or is presumed to have, a US beneficiary - US transferor treated as owner |
| §679(a)(4) 5-year look-back | Pre-immigration trust contributions - person becoming US resident treated as having made contributions to foreign trust as of residency start date for all contributions during 5 years prior to becoming resident |
| HIRE Act §643(i) - uncompensated use | Uncompensated use of foreign trust property by US grantor, US beneficiary, or related US person treated as distribution of FMV of use - reportable on Form 3520 (Part III) |
| HIRE Act §643(i)(2) - loans | Loans of cash or marketable securities from foreign trust to US person without market interest rate treated as distribution AND cause trust to be grantor trust (US beneficiary deemed) |
| US owner responsibility | US owner must ENSURE that foreign trust files Form 3520-A AND that owner/beneficiary statements are furnished - even though trust technically files |
| Filer identification | Foreign trust uses its EIN (not US owner's SSN); apply at IRS.gov/EIN or phone 267-941-1099 for foreign trusts |
| Signature | Trustee signs (partnership member or LLC member if partnership trustee; corporate officer if corporate trustee; receiver/fiduciary if applicable) |
| Form Part | Content |
|---|---|
| Part I - General Information | Trust name, EIN, address, country of creation, type, US agent appointment (if any) |
| Part II - Foreign Trust Income Statement | All trust income (interest, dividends, rents, capital gains, royalties); deductions; distributions; in USD using IRS yearly average exchange rates |
| Part III - Foreign Trust Balance Sheet | FMV of all assets and liabilities at beginning and end of tax year; in USD |
| Part IV - Excepted Specified Foreign Financial Assets | Checkbox if US owner duplicates reporting on Form 8938 - coordinates anti-duplication |
| Foreign Grantor Trust Owner Statement (pages 3-4) | One per US owner; reports trust income attributable to that owner; copy attached to that owner's Form 3520 Part II |
| Foreign Grantor Trust Beneficiary Statement (page 5) | One per US beneficiary receiving distribution; required if any US beneficiary received any distribution during year |
| US Agent Authorization (if appointed) | Form 3520-A statement authorizing US person to receive IRS communications and serve as record holder; re-attach every 3 years or upon material change |
| Attachments | Trust instrument copy (first year filed; subsequent years if amended); organizational charts for tiered structures; financial statements; explanation if no US agent |
| Deadline Element | Detail |
|---|---|
| Form 3520-A original deadline | 15th day of 3rd MONTH after trust's tax year-end (NOT 4th month like income tax returns) |
| Calendar-year trust 2025 | Due March 15, 2026 |
| Form 7004 extension | 6-month automatic extension to September 15 (for calendar-year trust); must be filed by March 15 deadline |
| Form 7004 EIN requirement | MUST use foreign trust's EIN, NOT US owner's SSN or ITIN. Form 7004 with US owner's SSN will be rejected |
| Substitute Form 3520-A deadline | Due with US owner's Form 3520 (October 15 for individuals with extension); NOT the 3520-A deadline |
| Form 3520 deadline | Same as US owner's income tax return (April 15) plus 6-month extension to October 15 via Form 4868 |
| Foreign-resident US owner | Automatic 2-month extension on Form 3520 to June 15; possible additional 2-month discretionary extension to December 15 for income tax return - but does NOT extend Form 3520 beyond October 15 |
| Where to file paper | Internal Revenue Service Center, P.O. Box 409101, Ogden, UT 84409 (verify current address in Form 3520-A instructions) |
| "Complete return" standard | Only a COMPLETE Form 3520-A is considered timely filed - missing pages 3-4 (owner statement) or page 5 (beneficiary statement) means form is INCOMPLETE and treated as not filed |
| Initial / final / amended boxes | Check "Initial return" first year; "Final return" if trust ceases; "Amended return" if amending previously filed |
| Substitute Element | Detail |
|---|---|
| Trigger | Foreign trustee FAILS to timely file Form 3520-A or fails to furnish owner/beneficiary statements |
| Who completes | US owner (NOT the trustee) completes substitute to best of their ability with available information |
| Signature | US owner signs the substitute - not the trustee |
| Filing | Attach substitute Form 3520-A to US owner's timely-filed Form 3520 (Box on Form 3520 line 22 checked "No") |
| Deadline | US owner's Form 3520 deadline - April 15 (or June 15 for foreign residents) with October 15 extension - NOT the Form 3520-A March 15 deadline |
| Penalty protection | Substitute filing protects US owner from §6677(b) 5% penalty for trust's failure to file |
| Best information available | If complete trust records unavailable, US owner reports what they have; includes statement explaining missing information; reasonable cause documentation prepared |
| Common scenario | Estranged family trust, deceased trustee, uncooperative foreign trustee, retroactive grantor classification from §679 5-year look-back |
| Practical limit | Substitute is a protection, not a license - US owner who cannot obtain trust records may face other compliance challenges (FBAR, Form 8938) |
| Penalty Element | Detail |
|---|---|
| Authority | IRC §6677 |
| Form 3520-A failure (US owner) | Greater of $10,000 OR 5% of gross value of trust portion attributable to US owner at end of tax year - applies for EACH year |
| Form 3520 failure to report transfers (transferor) | Greater of $10,000 OR 35% of gross value of contribution |
| Form 3520 failure to report distributions (US beneficiary) | Greater of $10,000 OR 35% of gross value of distribution |
| Form 3520 failure to report large foreign gift (US recipient) | 5% of gift amount for each month not reported (max 25%) |
| Additional penalties | If failure continues more than 90 days after notice, additional $10,000 per 30 days (capped at 100% of gross reportable amount under §6677(a)) |
| Reasonable cause defense §6677(d) | No penalty if failure due to reasonable cause and not willful neglect; reliance on foreign advisor or trustee's reluctance does NOT qualify; documented good-faith effort and substantive engagement required |
| IRS recent posture | IRS has been issuing automatic penalty notices and requiring TAXPAYER to assert reasonable cause for abatement; can result in immediate collection activity even pending abatement |
| Form 843 abatement | Used to request penalty abatement; supporting documentation; reasonable cause statement signed under penalty of perjury |
| First-time abate not available | First-Time Abate program does NOT cover §6677 penalties - reasonable cause is only path |
Facts: Anna, US citizen, inherited interest in foreign trust established by her Russian father in 2018. Father died in 2024. Trust holds $2,000,000 in foreign securities and real estate. Trust generated $80,000 of dividend/interest income for 2025. Anna is treated as grantor under §678 (she has unrestricted power over income) - actually, let's revise: Anna is treated as owner of 50% of the trust under §679 because she was the principal US beneficiary on death of grantor (Russian rules deemed her a beneficiary; she now has discretionary distributions). Foreign trustee is a Moscow lawyer.
2025 compliance requirements:
1. Form 3520-A: Foreign trust must file by March 15, 2026; trustee must include Foreign Grantor Trust Owner Statement for Anna and provide copy to Anna by March 15, 2026.
2. Form 3520: Anna must file by April 15, 2026 (or October 15 with extension); Part II reports her ownership; attaches Foreign Grantor Trust Owner Statement from Form 3520-A.
3. Form 1040: Anna includes $40,000 (50% of trust income) on her Schedule B and other applicable schedules; reports foreign tax credit if Russian tax withheld.
4. Form 8938 (FATCA): Anna's interest in trust value ($1,000,000 her share) exceeds threshold; required if she meets aggregate threshold.
5. FBAR (FinCEN 114): If trust holds foreign financial accounts and she has signature/financial interest, separate filing required.
What if foreign trustee fails to file Form 3520-A by March 15, 2026?
Anna prepares SUBSTITUTE Form 3520-A to the best of her ability using available trust records (statements, asset listings, accountant's reports). She SIGNS the substitute. She attaches it to her Form 3520 filed by October 15, 2026 (with extension). Line 22 on Form 3520 checked "No" indicating trustee failed to file; substitute attached.
Penalty protection: Substitute Form 3520-A timely filed with Form 3520 protects Anna from $10,000 minimum or 5% of $1,000,000 ($50,000) §6677 penalty. Without substitute: $50,000 automatic penalty notice.
Practical: Anna engages tax counsel; sends formal request to Moscow trustee with deadlines; documents communications for reasonable cause file. Prepares substitute regardless to maintain protection.
| §679 Element | Detail |
|---|---|
| Authority | IRC §679 (Foreign trusts having one or more US beneficiaries); Reg §1.679-1 through §1.679-7 (T.D. 8955 July 20 2001) |
| General rule §679(a)(1) | US person who transfers property to foreign trust treated as owner of trust portion attributable to transfer, provided trust has US beneficiary in any year |
| Presumption of US beneficiary §679(d) | Foreign trust presumed to have US beneficiary unless taxpayer demonstrates no portion of income or corpus may ever be paid to or accumulated for a US person |
| Indirect transfer §679(a)(3) | Transfer through intermediaries treated as direct transfer if intermediary is related party or part of plan |
| FMV exception §679(a)(2)(B) | NOT treated as owner if transferred property in exchange for FMV consideration - includes qualified obligations meeting Reg §1.679-4(d) specific terms |
| Qualified obligation §1.679-4(d) | Written express agreement; term not exceeding 5 years; market interest rate; principal and interest paid on schedule; not subordinated to other debts |
| §679(a)(4) 5-year look-back | Person becoming US resident treated as transferring trust contributions made during 5 years prior to residency start date; pre-immigration trust planning critical |
| Outbound trust §684 | Transfer of appreciated property to foreign trust by US person requires recognition of gain (unless grantor trust); applies at expatriation when US grantor status terminates |
| Cease being grantor trust §679(c)(2) | If trust ceases to have US beneficiary, grantor trust status terminates; if grantor was treated as owner, would have recognition of trust assets' value (gain only) |
| Coordination with §678 | §679 generally trumps §678; if both could apply, §679 governs (§6048 specifically excludes §678 from list of triggering grantor rules) |
| Rev. Proc. 2020-17 Element | Detail |
|---|---|
| Authority | Rev. Proc. 2020-17, 2020-12 IRB 539 (March 16, 2020); proposed regulations under §6048 (REG-124850-23) issued May 8, 2024 |
| Eligibility - "eligible individual" | US citizen or resident; current resident of country where foreign trust operates; complies with all foreign country tax laws relating to the foreign trust |
| "Tax-favored foreign retirement trust" | Country regulated; provides retirement, pension, or similar benefits OR is connected to government program; benefits limited and conditioned; contribution limits or tax favoritism imposed by foreign country |
| "Tax-favored foreign nonretirement savings trust" | Foreign trust for medical, disability, or educational benefits; country regulated; benefits limited and conditions imposed |
| Specific examples | UK ISAs (Individual Savings Accounts) - generally NOT covered (no specific benefit type limitation); UK Junior ISAs - may qualify under educational savings; Australian Super (some types may qualify); Canadian TFSAs - generally NOT covered (no specific benefit limitation); Norwegian BSU; Hong Kong MPF |
| Effect of exemption | Forms 3520 and 3520-A NOT required for transactions with or ownership of qualifying trust |
| Does NOT exempt from | FATCA Form 8938 reporting; FBAR FinCEN 114 reporting; trust income reporting on Form 1040 (Section 671-679 inclusion if grantor trust) |
| Penalty abatement for prior years | Eligible individuals who previously filed Forms 3520/3520-A for qualifying trusts may request penalty abatement under Rev. Proc. 2020-17 via Form 843 |
| One-time eligible election | Once made, applies to all subsequent years unless trust ceases to qualify |
| Documentation | Maintain trust plan documents; foreign country tax favoritism documentation; eligible individual residency documentation |
| RRSP/RRIF Element | Detail |
|---|---|
| Authority | Rev. Proc. 2014-55, 2014-44 IRB 753 (October 7, 2014); effective for tax years beginning after December 31, 2014 |
| Covered accounts | Canadian Registered Retirement Savings Plans (RRSPs) and Registered Retirement Income Funds (RRIFs) |
| NOT covered | Tax-Free Savings Accounts (TFSAs) - separate analysis; Registered Education Savings Plans (RESPs) - separate analysis; Registered Disability Savings Plans (RDSPs) |
| Effect | Eligible individuals NOT required to file Forms 3520 or 3520-A with respect to RRSPs/RRIFs |
| Automatic election relief | Automatic deferral of taxation on RRSP/RRIF earnings (no Form 8891 required); continues until distribution |
| Income reporting on distribution | Distributions taxable as ordinary pension income; treaty article XVIII coordinates pension recognition |
| FBAR still required | RRSP/RRIF balance over $10,000 USD aggregate with other foreign accounts → FBAR required |
| Form 8938 still potentially required | If aggregate specified foreign financial assets exceeds threshold for filing status |
| T.D. 10037 Element | Detail |
|---|---|
| Authority | Proposed regulations under §6048 issued May 8, 2024 (REG-124850-23); finalized as T.D. 10037 in January 2025 |
| Purpose | Modernize foreign trust reporting; clarify §679 application; codify Rev. Proc. 2020-17 exemption framework |
| Expanded exemption categories | Codifies and expands "tax-favored foreign trust" exemption beyond original Rev. Proc. 2020-17 scope |
| HIRE Act §643(i) implementation | Detailed rules for uncompensated use of trust property and below-market loans |
| §643(i) qualified obligation | Updated qualified obligation rules for loans from foreign trust to US persons |
| Reliance period | Taxpayers may rely on proposed regs for tax years ending after May 8, 2024 and beginning on or before publication of final regs |
| Foreign trust definition | Refinements to court test / control test boundaries under §7701(a)(31)(B) |
| Tiered trust structures | Look-through rules for foreign trust holding interests in other foreign trusts or entities |
| Documentation standards | Specific documentation requirements for substitute Form 3520-A filings |
| Coordination Element | Detail |
|---|---|
| FBAR (FinCEN 114) | If foreign trust holds foreign financial accounts and US person has signature or financial interest exceeding $10,000 aggregate; SEPARATE filing under 31 USC §5314, not coordinated with Forms 3520/3520-A |
| Form 8938 FATCA | US owner of foreign trust reports trust interest as specified foreign financial asset on Form 8938 if filing thresholds met; foreign trust itself may be reportable account if US owner has any portion |
| Anti-duplication | Form 3520-A Part IV checkbox if Form 8938 reports same trust (avoids double-counting in Form 8938 Part IV total) |
| Schedule B (Form 1040) | US owner must check "Yes" on Schedule B Line 8 regarding foreign trust grantor status / transfers / distributions |
| 1040 income inclusion | Foreign grantor trust income flows to US owner's Form 1040 - reported on appropriate schedules (B, D, E) based on character; Foreign Grantor Trust Owner Statement provides allocation |
| Foreign tax credit interaction | Foreign taxes paid by trust generally creditable to US owner under §901 / §903 to extent treated as owner; basket categorization under §904(d) |
| NIIT §1411 | 3.8% NIIT on trust investment income flowing to US owner; threshold MAGI applies |
Most common and costly error. Foreign trustee fails to file Form 3520-A; US owner unaware of substitute requirement; $10,000+ penalty notice arrives. Substitute attached to Form 3520 is protection. Even imperfect substitute filed timely beats no filing.
Form 7004 must use FOREIGN TRUST's EIN, not US owner's SSN/ITIN. Form 7004 with US owner's SSN gets rejected as unprocessable; extension treated as not filed; trust deadline missed.
Only COMPLETE Form 3520-A is timely. Missing Owner Statement (pages 3-4) or Beneficiary Statement (page 5) means form is treated as not filed - even if other parts perfectly completed. Penalties apply.
Form 3520-A: foreign TRUST files annually. Form 3520: US PERSON files annually reporting transactions, gifts, ownership. BOTH required for foreign grantor trust with US owner. Filing only one is insufficient and triggers penalties for the missing form.
Rev. Proc. 2014-55 exempts RRSPs/RRIFs from Form 3520/3520-A, NOT from FBAR and NOT from Form 8938. Practitioners often think the exemption is universal. FBAR still required if account balance ≥ $10,000 USD; Form 8938 still required if aggregate threshold met.
Rev. Proc. 2014-55 covers RRSPs and RRIFs ONLY. Canadian TFSAs (Tax-Free Savings Accounts), RESPs (Registered Education Savings Plans), and RDSPs (Registered Disability Savings Plans) require Form 3520/3520-A analysis. Some may qualify under Rev. Proc. 2020-17 if eligible individual / tax-favored trust requirements met; others require full reporting.
Pre-immigration trust contributions during 5 years before becoming US resident triggered as if made on residency start date. New US residents with home-country trusts often miss this lookback - first US tax year shows substantial inclusion. Pre-immigration planning critical.
Foreign Grantor Trust Owner Statement (pages 3-4) for US owner who reports trust income. Foreign Grantor Trust Beneficiary Statement (page 5) for US beneficiary receiving distribution (if trust is grantor trust, distributions to owner are not separately taxable; distributions to non-owner US beneficiaries are gifts from grantor for tax purposes).
Foreign trust may have non-calendar tax year (e.g., April-March in UK). Form 3520-A due 15th day of 3rd month after foreign trust's tax year-end, NOT US owner's tax year. Practitioner using US owner's tax year may miss correct deadline.
IRS does NOT accept "I relied on foreign advisor / trustee" as reasonable cause for §6677 penalty abatement. Defenses must show specific good-faith engagement, qualified US tax advisor consultation, and reasonable steps despite trust's foreign location.
HIRE Act 2010 §533 - uncompensated use of foreign trust property by US grantor, US beneficiary, or related US person is treated as distribution at FMV of use. US owner using trust-owned vacation home, boat, art collection without paying FMV = distribution. Reported on Form 3520 Part III.
Loan of cash or marketable securities from foreign trust to US person without market interest rate is treated as distribution AND triggers grantor trust status (US beneficiary deemed present). Common with cross-border family wealth structures. Must be documented as qualified obligation under Reg §1.679-4(d) to avoid this trap.
US person transferring appreciated property to foreign trust may trigger §684 immediate gain recognition (treated as sale) - except when US person is treated as owner of trust under grantor trust rules. Common error - moving appreciated stock to foreign trust without recognizing §684 implications.
Foreign trust generally uses calendar year unless §644 election to use fiscal year. Election bound; can affect Form 3520-A deadline. Trustee election should be documented.
Some IGAs (Intergovernmental Agreements under FATCA) provide specific reporting relief for foreign retirement plans. RA-protected accounts may not require Form 8938 reporting but still require Form 3520/3520-A unless Rev. Proc. 2020-17 covers them.
Foreign trustee resigns mid-year; new trustee may not have full historical records; Form 3520-A still due on regular deadline. US owner should obtain trust records pre-resignation; document transition; consider substitute filing if records incomplete.
Primary authority: IRC §6048 (Information with respect to foreign trusts - reporting requirements). §6048(a) (notice of certain transfers). §6048(b) (annual information return - foreign trust with US owner). §6048(c) (US person receiving distribution). §6677 (penalties for failure to file information returns - greater of $10,000 or 5% of trust value for 3520-A failure; 35% for 3520 transfer/distribution failures). §6677(a) (general penalty rule). §6677(b) (additional penalty for continued failure after 90-day notice - up to 100% of gross reportable amount). §6677(d) (reasonable cause exception). §671 (trust income, deductions, credits attributable to grantors). §672 (definitions and rules - grantor trust). §673 (reversionary interests). §674 (power to control beneficial enjoyment). §675 (administrative powers). §676 (power to revoke). §677 (income for benefit of grantor). §678 (person other than grantor treated as substantial owner - excluded for §6048 purposes). §679 (foreign trusts having one or more US beneficiaries). §679(a)(1) (general rule). §679(a)(2) (exceptions - transfer at FMV, certain sales/exchanges). §679(a)(2)(B) (qualified obligations). §679(a)(3) (transfers by reason of death). §679(a)(4)(A) (5-year look-back for pre-immigration transfers). §679(c)(2) (US beneficiary presumption rules). §679(d) (presumption that US beneficiary exists). §684 (recognition of gain on transfer to foreign trust - except grantor trust). §643(i) (uncompensated use of trust property treated as distribution - HIRE Act §533). §643(i)(2) (loans of cash or marketable securities treated as distribution). §644 (taxable year of trusts - generally calendar year). §6038D (specified foreign financial asset reporting - Form 8938). §7701(a)(31)(B) (foreign trust definition). §901, §903, §904 (foreign tax credit - basketing of trust foreign taxes). §1411 (NIIT - 3.8% on trust investment income flowing to US owner). §2801 (transfer tax on covered gifts/bequests from covered expatriates - separate from §6048). §2503(b) (annual gift exclusion). Reg §1.679-1 through §1.679-7 (T.D. 8955 July 20 2001 - §679 grantor rules). Reg §1.6048-1 (proposed) through Reg §1.6048-5 (proposed - REG-124850-23 May 8 2024). Reg §301.7701-7 (foreign trust definition - court test, control test). Notice 97-34, 1997-1 CB 422 (Form 3520/3520-A guidance). Notice 2009-85 (§877A expatriation guidance - trust coordination). Revenue Procedure 2014-55, 2014-44 IRB 753 (Canadian RRSP/RRIF exemption from Forms 3520/3520-A). Revenue Procedure 2020-17, 2020-12 IRB 539 (March 16, 2020 - tax-favored foreign retirement and nonretirement savings trust exemption). Treasury Decision 10037 (January 2025 - proposed §6048 regulations finalized). Treasury Decision 8955 (July 20, 2001 - §679 regulations). 31 USC §5314 (FBAR authority). 31 CFR §1010.350 (FBAR reporting). Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts). Form 3520-A (Annual Information Return of Foreign Trust With a US Owner). Form 7004 (extension for business returns - including Form 3520-A). Form 8938 (Statement of Specified Foreign Financial Assets). Form 8833 (Treaty-Based Return Position Disclosure - some treaty positions). Form 843 (Claim for Refund and Request for Abatement). Form 8891 (obsolete - was Canadian retirement plan election; superseded by Rev. Proc. 2014-55). Heroes Earnings Assistance and Relief Tax Act of 2008 (HIRE Act - P.L. 110-245 - added §877A and §643(i) provisions). Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, P.L. 114-41 (modified Form 3520/3520-A due dates).