May 8, 2024 This week, the Treasury Department and the IRS released proposed regulations for transactions with foreign trusts and 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’ 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 in the near future.
