Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
You are (a) a U.S. person (including a U.S. owner) or an executor of the estate of a U.S. person who, during the current tax year, received, directly
or indirectly, a distribution from a foreign trust; (b) a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year,
you or a U.S. person related to you received (1) a loan of cash or marketable securities, directly or indirectly, from such foreign trust, or (2) the
uncompensated use of trust property; or (c) a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year such
foreign trust holds an outstanding qualified obligation of yours or a U.S. person related to you. Complete all applicable identifying information
requested below and Part III of the form.
You are a U.S. person who, during the current tax year, received certain gifts or bequests from a foreign person. Complete all applicable
identifying information requested below and Part IV of the form.
1a Name of U.S. person(s) with respect to whom this Form 3520 is being filed (see instructions) b Taxpayer identification number (TIN)
c Number, street, and room or suite no. If a P.O. box, see instructions. d Spouse’s TIN
i If you are filing with your spouse a current-year joint income tax return and a joint Form 3520, check this box . . . . . . . . .
j If an automatic 2-month extension applies for the U.S. person’s tax return, check this box and attach statement. See instructions . . .
k If an extension was requested for the tax return, check this box and enter the form number of the tax return to be filed:
2a Name of foreign trust (if applicable) b Employer identification number (EIN), if any
c Number, street, and room or suite no. If a P.O. box, see instructions. d Date foreign trust was created
3 Did the foreign trust appoint a U.S. agent (defined in the instructions) who can provide the IRS with all relevant trust information? Yes No
If “Yes,” complete lines 3a through 3g. If “No,” and you are required to complete Part I, complete lines 15 through 18.
3a Name of U.S. agent b TIN, if any
c Number, street, and room or suite no. If a P.O. box, see instructions.
6a Country code of country where trust was created b Country code of country whose law governs the trust c Date trust was created
7a Will any person (other than the foreign trust) be treated as the owner of the transferred assets after the transfer? . . . . Yes No
b (i) (ii) (iii) (iv) (v)
Name of foreign Relevant Code
trust owner Address Country of residence TIN, if any section
8 Was the transfer a completed gift or bequest? If “Yes,” see instructions . . . . . . . . . . . . . . . . Yes No
9a Now or at any time in the future, can any part of the income or corpus of the trust benefit any U.S. beneficiary? . . . . Yes No
b If “No,” could the trust be revised or amended to benefit a U.S. beneficiary? . . . . . . . . . . . . . . Yes No
10 Reserved for future use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
Schedule A—Obligations of a Related Trust (see instructions)
11a During the current tax year, did you transfer property (including cash) to a related foreign trust in exchange for an obligation
of the trust or an obligation of a person related to the trust? See instructions . . . . . . . . . . . . . . Yes No
If “Yes,” complete the rest of Schedule A, as applicable. If “No,” go to Schedule B.
b Were any of the obligations you received (with respect to a transfer described in line 11a above) qualified obligations? . . Yes No
If “Yes,” complete the rest of Schedule A and attach a copy of each loan document entered into with respect to each
qualified obligation reported on line 11b. If these documents have been attached to a Form 3520 filed within the previous 3
years, attach only relevant updates.
If “No,” go to Schedule B.
(i) (ii) (iii) (iv)
Date of transfer giving rise to obligation Maximum term Yield to maturity FMV of obligation
12 With respect to each qualified obligation you reported on line 11b, do you agree to extend the period of assessment of any
income or transfer tax attributable to the transfer, and any consequential income tax changes for each year that the
obligation is outstanding, to a date 3 years after the maturity date of the obligation? . . . . . . . . . . . . Yes No
Note: You have the right to refuse to extend the period of limitations or limit this extension to a mutually agreed-upon
issue(s) or mutually agreed-upon period of time. Generally, if you refuse to extend the period of limitations with respect to
each qualified obligation you reported on line 11b, then such obligation is not a qualified obligation and you cannot check
“Yes” to the question on line 11b.
Schedule B—Gratuitous Transfers (see instructions)
13 During the current tax year, did you make any transfers (directly or indirectly) to the trust and receive less than FMV, or no
consideration at all, for the property transferred? . . . . . . . . . . . . . . . . . . . . . . Yes No
If “Yes,” complete columns (a) through (i) below and the rest of Schedule B, as applicable. When completing columns (a)
through (i) with respect to each nonqualified obligation, enter -0- in column (h).
If “No,” go to Schedule C.
(a) (b) (c) (d) (e) (f) (g) (h) (i)
Date of Description FMV of property U.S. adjusted Gain recognized Excess, if any, Description FMV of property Excess of
transfer of property transferred basis of at time of of column (c) of property received column (c) over
transferred property transfer, over the sum of received, column (h)
transferred if any columns (d) and (e) if any
Totals $ $
14 If you have a sale or loan document in connection with a transfer reported on line 13, complete 14a through 14c and attach the relevant
document(s). If these documents have been attached to a Form 3520 filed within the previous 3 years, attach only relevant updates.
Attached Year
Are you attaching a copy of any of the following? Yes No Previously Attached
a Sale document . . . . . . . . . . . . . . . . . . . . . . . .
b Loan document . . . . . . . . . . . . . . . . . . . . . . . .
c Subsequent variances to original sale or loan documents . . . . . . . . . . . .
Form 3520 (Rev. 12-2023)
Form 3520 (Rev. 12-2023) Page 3
Part I Schedule B—Gratuitous Transfers (continued)
Note: Complete lines 15 through 18 only if you are required to complete Part I and answered “No” to line 3, acknowledging that the foreign trust did
not appoint a U.S. agent to provide the IRS with all relevant trust information.
15 (a) (b) (c) (d)
Name of beneficiary Address of beneficiary U.S. beneficiary? TIN, if any
Yes No
18 If you checked “No” on line 3, you are required to attach a copy of all trust documents as indicated below. If these documents have been
attached to a Form 3520-A or Form 3520 filed within the previous 3 years, attach only relevant updates.
Attached Year
Are you attaching a copy of any of the following? Yes No Previously Attached
a Summary of all written and oral agreements and understandings relating to the trust . . . .
b Trust instrument . . . . . . . . . . . . . . . . . . . . . . . .
c Memoranda or letters of wishes . . . . . . . . . . . . . . . . . . . .
d Subsequent variances to original trust documents . . . . . . . . . . . . . .
e Trust financial statements . . . . . . . . . . . . . . . . . . . . .
f Organizational chart and other trust documents . . . . . . . . . . . . . . .
Schedule C—Qualified Obligations Outstanding in the Current Tax Year (see instructions)
19 Did you, at any time during your tax year, hold an outstanding obligation of a related foreign trust (or a person related to the
trust) that you reported as a qualified obligation in the current tax year? . . . . . . . . . . . . . . . . Yes No
If “Yes,” complete columns (a) through (f) below for each obligation.
(f)
(a) (b) (c) (d) (e) Does the obligation
Date of original Tax year qualified Amount of principal Amount of interest Balance of the outstanding still meet the
obligation obligation first reported payments made during payments made during obligation at the end criteria for a
your tax year your tax year of the tax year qualified obligation?
Yes No
21a Country code of country where foreign trust was created b Country code of country whose law governs the trust c Date foreign trust was created
22 Did the foreign trust file Form 3520-A for the current tax year? . . . . . . . . . . . . . . . . . . . Yes No
If “Yes,” attach the Foreign Grantor Trust Owner Statement you received from the foreign trust.
If “No,” to the best of your ability, complete and attach a substitute Form 3520-A for the foreign trust.
See instructions for information on penalties for failing to complete and attach a substitute Form 3520-A.
23 Enter the gross value of the portion of the foreign trust that you are treated as owning at the end of your tax year . . $
Part III Distributions to a U.S. Person From a Foreign Trust During the Current Tax Year (see instructions)
Note: If you received an amount from a portion of a foreign trust of which you are treated as the owner, only complete lines 24 and 27.
24 Enter cash amounts or FMV of property received, directly or indirectly, during your current tax year, from the foreign trust (exclude loans and
uncompensated use of trust property included on line 25).
(a) (b) (c) (d) (e) (f)
FMV of property received
Date of distribution Description of property received (determined on date Description of property FMV of property Excess of column (c)
of distribution) transferred, if any transferred over column (e)
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $
25 During your current tax year, did you (or a person related to you) receive a loan or uncompensated use of trust property from a
related foreign trust (including an extension of credit upon the purchase of property from the trust)? . . . . . . . . Yes No
If “Yes,” complete columns (a) through (g) below for each such loan or use of trust property.
Note: See instructions for additional information, including how to complete columns (a) through (g) for use of trust property.
(c) (e) (g)
(a) (b) (d) (f) Amount treated as
Maximum term of Is the obligation a
FMV of loan proceeds Date of original Interest rate qualified obligation? FMV of qualified distribution from the trust
or property transaction repayment of of obligation obligation (subtract column (f)
obligation Yes No from column (a))
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $
26 With respect to each obligation you reported as a qualified obligation on line 25, do you agree to extend the period of
assessment of any income or transfer tax attributable to the transaction, and any consequential income tax changes for each
year that the obligation is outstanding, to a date 3 years after the maturity date of the obligation? . . . . . . . . . Yes No
Note: You have the right to refuse to extend the period of limitations or limit this extension to a mutually agreed-upon issue(s)
or mutually agreed-upon period of time. Generally, if you refuse to extend the period of limitations with respect to an obligation
that you reported as a qualified obligation on line 25, then such obligation is not a qualified obligation and you cannot check
“Yes” in column (e) of line 25.
27 Total distributions received during your current tax year. Add line 24, column (f), and line 25, column (g) . . . . . $
28 Did the trust, at any time during the current tax year, hold an outstanding obligation of yours (or a person related to you) that
you reported as a qualified obligation? . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If “Yes,” complete columns (a) through (f) below for each obligation.
(f)
(a) (b) (c) (d) (e) Does the loan still
Date of original Tax year qualified Amount of principal payments Amount of interest payments Balance of the outstanding meet the criteria of a
loan transaction obligation first made during your tax year made during your tax year obligation at the end qualified obligation?
reported of the tax year
Yes No
Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $
55 During your current tax year, did you receive amounts from a foreign corporation or a foreign partnership that you treated as
gifts in excess of the amount provided in the instructions? See instructions regarding related donors . . . . . . . Yes No
If “Yes,” complete columns (a) through (g) with respect to each such gift. If more space is needed, attach a statement.
(a) (b) (c) (d)
Date of gift Name of foreign donor Address of foreign donor TIN, if any
(e)
Check the box that applies to the foreign donor (f) (g)
Description of property received FMV of property received
Corporation Partnership
56 Do you have any reason to believe that the foreign donor, in making any gift or bequest described in lines 54 and 55, was
acting as a nominee or intermediary for any other person? If “Yes,” see instructions . . . . . . . . . . . . Yes No
Under penalties of perjury, I declare that I have examined this return, including any accompanying reports, schedules, or statements, and to the best of my
Sign knowledge and belief, it is true, correct, and complete.
Here
Signature Title Date
Print/Type preparer’s name Preparer’s signature Date Check if PTIN
Paid self-employed
Preparer
Firm’s name Firm’s EIN
Use Only
Firm’s address Phone no.
Form 3520 (Rev. 12-2023)