There May Be 50 Ways To Leave Your Lover But You May Only Utilize A CDP Challenge to Contest a Form 3520 Penalty Without Prepayment

There May Be 50 Ways To Leave Your Lover But You May Only Utilize A CDP Challenge to Contest a Form 3520 Penalty Without Prepayment

Tax Law
By Anthony Diosdi Under Internal Revenue Code Section 6677(a), if any United States Person beneficiary receives (directly or indirectly) a distribution from a foreign trust, that person is required to make a return with respect to such a trust using Internal Revenue Service (“IRS”) Form 3520, and show thereon the name of the trust, the amount of the aggregate distribution received, and any other data the IRS may require. A foreign gift, bequest, or inheritance that exceeds $100,000 must also be disclosed on a Form 3520. The IRS may assess an annual penalty equal to 35 percent of the gross value of the trust or 35 percent of the gross value of the property transferred from the trust if a Form 3520 is not timely filed. The IRS may also…
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Relief from Filing Forms 3520 and Form 3520-A for Some

Relief from Filing Forms 3520 and Form 3520-A for Some

Tax Law
By Anthony Diosdi The Internal Revenue Code provides that if any United States Person (i.e. U.S. citizen or U.S. resident) beneficiary receives (directly or indirectly) a distribution from a foreign trust during any taxable year, such person is required to make a return with respect to such a trust for such year using Internal Revenue Service (“IRS”) Form 3520, and show thereon the name of the trust, the amount of the aggregate distribution received, and any other data the IRS may require. The IRS may assess an annual penalty equal to 35 percent of the gross value of the trust. See IRC Section 6048(c).The Internal Revenue Code also provides that each U.S. Person treated as an owner of any portion of a foreign trust under Internal Revenue Code Section 671…
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