Form 3520 and 3520-A: Foreign Trust and Gift Reporting Practitioner Guide

Foreign trust reporting and foreign gift reporting sit among the most heavily penalized compliance areas in the Internal Revenue Code. The IRC 6677 penalty structure, at 35% of the gross reportable amount for an initial failure, is one of the harshest information-return penalty regimes in the Code. Form 3520 and Form 3520-A impose layered obligations on U.S. transferors, U.S. owners, and U.S. beneficiaries of foreign trusts, as well as on U.S. persons who receive large gifts or bequests from foreign persons. This guide is written for enrolled agents, CPAs, and tax attorneys who need a precise, citation-anchored reference for these obligations, their deadlines, their penalties, and the compliance strategies that apply in 2026.

All statutory citations, regulatory references, and IRS procedural guidance referenced in this guide must be verified against current law, current IRS.gov instructions, and applicable Treasury regulations before being relied on in any specific client matter. Tax law in the international information return space is subject to ongoing regulatory development, including the pending May 2024 proposed regulations under IRC 6048. Nothing in this guide constitutes legal or tax advice; each client matter requires independent analysis by a qualified practitioner.

Section 1: Why Form 3520 Matters in 2026

Foreign trusts and large foreign gifts are two of the highest-penalty compliance areas for individual taxpayers in the entire Internal Revenue Code. The IRC 6677(a) penalty of 35% of the gross reportable amount is not a percentage of tax owed; it is a percentage of the full value of the unreported transaction. A U.S. person who receives a $500,000 foreign gift and fails to report it on Form 3520 faces a potential penalty of $175,000, regardless of whether any income tax is owed on the gift. A person who receives a $2 million foreign gift faces a potential penalty of $700,000. These are not hypothetical outcomes. The IRS has been actively assessing IRC 6677 penalties and litigating them in Tax Court and the federal courts.

Increased IRS Enforcement Attention Since FATCA

The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, dramatically expanded the IRS's access to information about foreign financial accounts, foreign trusts, and large foreign transfers. Foreign financial institutions report U.S. account holders and their balances to the IRS under the FATCA intergovernmental agreement network. The IRS cross-references FATCA data against Form 3520 and Form 3520-A filings to identify unreported foreign trust relationships and large unreported foreign transfers.

For practitioners advising clients with international connections, FATCA data sharing has fundamentally changed the compliance landscape. The IRS is no longer relying solely on voluntary disclosure; it has a data-driven identification system for foreign trust and foreign gift non-filers. See the related FBAR, FATCA, Form 114, and Form 8938 foreign information reporting practitioner guide for a full discussion of FATCA's reporting requirements and their relationship to the broader international information return network.

Two Major Developments Practitioners Must Know

Two recent developments require attention from any practitioner advising international clients on Form 3520 or Form 3520-A obligations:

• Proposed regulations (May 2024): The IRS published proposed regulations under IRC 6048 and related provisions that would revise the reporting requirements for foreign trusts and gifts. As of July 2026, these regulations have NOT been finalized, but practitioners should understand what changes they propose and monitor IRS.gov for finalization. See Section 7 of this guide.
• Updated Form 3520 and 3520-A instructions (December 2025): The IRS issued revised instructions for both forms in December 2025. These updated instructions are the current operative guidance for all line-level compliance. Practitioners must use the December 2025 (or later) version of the instructions from IRS.gov, not prior-year versions.

Section 2: Form 3520 -- What Triggers a Filing Obligation

Form 3520 is not limited to a single type of reportable event. Three separate categories of transactions with or involving foreign parties can independently trigger a Form 3520 filing requirement. A single U.S. person may have reportable events in more than one category in the same tax year; a single Form 3520 can report multiple types of events.

Category A: Transactions with a Foreign Trust as a U.S. Transferor or Owner (IRC 6048(a) and IRC 6048(b))

A U.S. person who transfers money or property to a foreign trust, or who is treated as the owner of a foreign trust under the grantor trust rules (IRC 671-679), must file Form 3520 for each tax year in which such a transfer or ownership relationship exists. The reporting obligation applies whether or not any income is recognized or any distribution is received in the tax year. Cite IRC 6048(a) for transferors and IRC 6048(b) for U.S. owners; hedge to current Form 3520 instructions on IRS.gov for specific reporting line requirements.

Category B: Receipt of a Large Foreign Gift or Bequest (IRC 6039F)

A U.S. person who receives a gift or bequest from a foreign person that exceeds the applicable threshold under IRC 6039F must file Form 3520 to report the receipt. Two separate thresholds apply, and they are distinct:

• Threshold for gifts from nonresident alien individuals or foreign estates: A separate reporting threshold applies to this category. Confirm the current threshold amount at IRS.gov and the current Form 3520 instructions before advising any client. Do NOT rely on any dollar figure stated here or elsewhere without verifying the current amount, as this threshold is subject to adjustment.
• Threshold for gifts from foreign corporations or foreign partnerships: A different (and generally lower, on a per-year aggregate basis) threshold applies to gifts from foreign corporations or foreign partnerships. This threshold is also confirmed at IRS.gov and current Form 3520 instructions. The two thresholds are completely separate; receiving a gift from a foreign individual does not count toward the threshold for gifts from foreign entities, and vice versa. Practitioners must evaluate both categories independently for each client and tax year.

Once either applicable threshold is exceeded in a tax year, the U.S. person must report the entire amount received from that category (not just the excess) on Form 3520. Aggregation rules apply to gifts from related foreign parties; hedge the aggregation rules to current Form 3520 instructions and IRS.gov.

Category C: Distributions from a Foreign Trust to a U.S. Beneficiary (IRC 6048(c))

A U.S. person who receives a distribution from a foreign trust must report the full amount of the distribution on Form 3520 under IRC 6048(c), regardless of the income tax treatment of the distribution. The distribution may consist of ordinary income, capital gain, return of corpus (basis), or a combination. The income tax characterization is determined under separate rules; the Form 3520 reporting obligation covers the full distribution amount. Hedge the specific reporting requirements for trust distributions to IRS.gov and current Form 3520 instructions.

Due Date for Form 3520

Form 3520 is generally due on the same date as the U.S. person's income tax return, including any extensions. For most calendar-year individual taxpayers, this means April 15 of the year following the tax year, or October 15 if an extension has been obtained. Form 3520 is filed separately from the income tax return; it is NOT attached to Form 1040. It is mailed to a separate IRS processing address specified in the current Form 3520 instructions. Cite IRC 6048 and verify the current filing address and any electronic filing options at IRS.gov.

Section 3: Form 3520-A -- The Trust's Annual Return

Form 3520-A is a distinct and separate form from Form 3520. While Form 3520 is filed by the U.S. person (transferor, owner, or beneficiary), Form 3520-A is the annual information return of the foreign trust itself. The obligation to file Form 3520-A rests primarily with the foreign trust, not with any individual U.S. person, but when the trust fails to file, the U.S. owner bears the responsibility for filing a substitute.

Who Files Form 3520-A

Under IRC 6048(b), the foreign trust is required to file Form 3520-A annually for each year it has a U.S. owner (a U.S. person treated as owner under IRC 671-679). If the foreign trust does not file Form 3520-A, the U.S. owner is responsible for filing a substitute Form 3520-A that contains all the information that the trust would have been required to report. The substitute must be attached to the U.S. owner's Form 3520. In practice, many foreign trusts do not file Form 3520-A; U.S. practitioners advising U.S. owners of foreign grantor trusts must plan for the substitute filing obligation and obtain the necessary trust records from the trustee.

Due Date for Form 3520-A

For calendar-year foreign trusts, Form 3520-A is due March 15, which is an earlier deadline than Form 3520 (due April 15 or October 15 with extension). An extension to September 15 is available. Cite IRC 6048(b) and hedge to the current Form 3520-A instructions on IRS.gov for current extension procedures and filing addresses. Note that the March 15 due date for Form 3520-A creates a two-month gap before the April 15 deadline for Form 3520; both forms require coordination and the earlier deadline must not be overlooked.

What Form 3520-A Reports

Form 3520-A is substantially more complex than Form 3520. The form requires detailed information about the foreign trust's assets, income (both from U.S. and non-U.S. sources), distributions made during the year, and the ownership interests of U.S. persons. The form includes a Foreign Grantor Trust Owner Statement, which the trust must provide to each U.S. owner to allow them to satisfy their U.S. income tax obligations. Obtaining this information from a foreign trustee can be operationally challenging; practitioners should advise U.S. clients who own or create foreign trusts to negotiate trustee cooperation obligations at the time of trust formation.

December 2025 Updated Instructions

The IRS issued updated Form 3520-A instructions in December 2025. Practitioners must use the most current version from IRS.gov for all line-level requirements. Prior-year instructions may not accurately reflect current reporting requirements. All substantive line-level guidance in this guide hedges to the current Form 3520-A instructions on IRS.gov.

Section 4: Grantor Trust vs. Non-Grantor Trust

The distinction between a foreign grantor trust and a foreign non-grantor trust is fundamental to understanding which forms are required, which penalties can apply, and how the income from the trust is taxed in the United States. This determination is not always straightforward and may require a careful analysis of the trust instrument, the trust's assets, and the grantor trust rules under IRC 671-679.

Foreign Grantor Trust: U.S. Owner Under IRC 671-679

If a U.S. person is treated as the owner of a foreign trust under the grantor trust rules (IRC 671-679), the following reporting obligations apply:

• The U.S. owner must file Form 3520 reporting the existence of the foreign trust, any transfers to the trust, and any trust distributions received. IRC 6048(b).
• The foreign trust must file Form 3520-A annually. If the trust does not file, the U.S. owner files a substitute Form 3520-A. IRC 6048(b).
• As the deemed owner of the trust's assets under the grantor trust rules, the U.S. person must include the trust's income, deductions, and credits in their own U.S. income tax return for each year of ownership.

IRC 679: The Anti-Deferral Rule for U.S. Transferors

IRC 679 is a particularly important provision for U.S. persons who create or fund foreign trusts. Under IRC 679, a U.S. person who transfers property to a foreign trust that has a U.S. beneficiary is treated as the owner of the transferred property for U.S. income tax purposes, regardless of the actual terms of the trust. This is an anti-deferral rule that prevents U.S. taxpayers from avoiding current U.S. taxation by placing income-producing assets in offshore trusts. The rule applies regardless of whether the U.S. transferor retains any formal rights over the trust or its assets.

A U.S. person subject to IRC 679 is both a transferor (required to file Form 3520 under IRC 6048(a)) and a deemed owner (required to file Form 3520 and whose trust is required to file Form 3520-A under IRC 6048(b)). The income tax and reporting consequences run concurrently. Hedge all IRC 679 analysis to the statute and current IRS.gov guidance; the application of IRC 679 in specific trust structures can be complex.

Foreign Non-Grantor Trust: U.S. Beneficiary Under IRC 6048(c)

If the foreign trust is NOT a grantor trust with respect to any U.S. person (a non-grantor trust), the trust is treated as a separate taxable entity. U.S. beneficiaries who receive distributions from a foreign non-grantor trust must report those distributions on Form 3520 under IRC 6048(c). The reporting obligation applies to the full distribution amount, regardless of how the distribution is characterized for income tax purposes.

The income tax treatment of distributions from a foreign non-grantor trust is governed by separate rules under Subchapter J (IRC 641-692), including the throwback rules.

Accumulation Distribution Rules (IRC 665-668): The Throwback Tax

Foreign non-grantor trusts are subject to the accumulation distribution rules under IRC 665-668. These rules are sometimes called the "throwback rules" because they effectively reach back to prior tax years when the trust accumulated income that was not distributed. When a foreign non-grantor trust that has accumulated undistributed net income (UNI) makes a distribution to a U.S. beneficiary, the distribution is "thrown back" to the years in which the income was earned, and the U.S. beneficiary may be subject to an additional income tax plus an interest charge (the "throwback tax" and the IRC 668 interest charge) computed as if the income had been distributed in the year it was earned.

The throwback tax calculation is complex and requires information about the trust's income history. Hedge all specifics of the throwback computation to IRC 665-668 and current IRS.gov guidance. Practitioners advising U.S. beneficiaries of foreign non-grantor trusts should obtain the trust's historical income records before computing the income tax consequences of any distribution.

Section 5: Penalties Under IRC 6677

The penalties for failure to file Form 3520 and Form 3520-A are among the most severe in the international information return penalty regime. The defining characteristic of the IRC 6677 penalty structure is that it is calculated as a percentage of the gross reportable amount, not as a percentage of any unpaid tax. Because foreign gifts and large trust transactions often involve substantial dollar values, the resulting penalty can be severe even in cases where no income tax is owed at all.

Initial Failure to File: 35% of the Gross Reportable Amount (IRC 6677(a))

Under IRC 6677(a), the penalty for failure to file Form 3520 reporting a foreign trust transaction or a foreign gift is 35% of the gross reportable amount. The "gross reportable amount" is the total value of the transaction that should have been reported on Form 3520. For a foreign gift, this is the full value of the gift received. For a trust transfer, it is the total amount transferred. For a trust distribution, it is the full distribution amount.

Practical illustration: A U.S. person receives a $1,000,000 foreign gift from a nonresident alien parent and fails to file Form 3520. The initial IRC 6677(a) penalty is 35% of $1,000,000, which equals $350,000. No income tax is owed on the gift under IRC 102(a), but the failure-to-report penalty is $350,000. This outcome illustrates why the IRC 6677 penalty structure is one of the harshest in the Code: the penalty bears no relationship to any tax liability; it is a pure information-reporting penalty calculated against the full transaction value.

Hedge all penalty amounts, rates, and procedures to IRC 6677 and IRS.gov. The statute is controlling and may be updated by legislative change. Confirm current penalty amounts at IRS.gov before advising any client.

Continuing Penalty for Late Filings After IRS Notice

In addition to the initial 35% penalty, an additional percentage of the gross reportable amount may apply for each month the failure to file continues after the IRS issues a notice of the failure. The specific monthly rate and the statutory maximum applicable to continuing failures are set out in IRC 6677. Hedge the exact rate and cap to IRC 6677 and IRS.gov, as these details are statutory and may be updated. Practitioners advising a client who has received an IRS notice of failure to file Form 3520 should treat prompt remediation as urgent, as the continuing penalty accrues monthly.

Form 3520-A Penalties (IRC 6677(b))

Separate penalties apply under IRC 6677(b) for failure to file Form 3520-A (or a substitute). These are distinct from the Form 3520 penalties and apply separately to the trust's annual reporting obligation. The penalty framework for Form 3520-A failures mirrors the Form 3520 structure (a percentage of the gross reportable amount), but the base amount may differ. Hedge the Form 3520-A penalty rates and procedures to IRC 6677(b) and IRS.gov.

Statutory Minimum Penalty

IRC 6677 also provides for a statutory minimum penalty in certain circumstances. Hedge the minimum penalty amount and its application to IRC 6677 and IRS.gov; the minimum penalty is established by statute and may be modified by legislative change.

No Income Tax Owed, But Penalty Still Applies

A critical and frequently misunderstood point: a U.S. person who receives a large foreign gift owes no federal income tax on the gift itself under IRC 102(a). The gift is excluded from gross income. However, the exclusion from income tax has no bearing on the Form 3520 reporting obligation or the IRC 6677 penalty. The penalty exists to enforce the information reporting requirement, not to collect tax. A client who correctly understands that a foreign gift is "not taxable" and therefore concludes that no tax forms are required is incorrect and at risk of the full IRC 6677 penalty. This distinction must be communicated clearly to every client who receives a large foreign gift or bequest.

Section 6: Reasonable Cause Defense

The IRS may abate a Form 3520 or Form 3520-A penalty if the taxpayer establishes that the failure was due to reasonable cause and not willful neglect, under IRC 6677(d). The reasonable cause defense is a critical tool for practitioners representing clients who missed the filing deadline or failed to file at all, but it is not a guaranteed remedy. The IRS has been historically strict in applying this standard to international information return penalties.

What Constitutes Reasonable Cause

Reasonable cause for an IRC 6677 penalty failure is a facts-and-circumstances determination. Circumstances that may support a reasonable cause argument include:

• A genuine, good-faith uncertainty about whether the filing obligation applied to the taxpayer's specific situation.
• Reliance on advice from a qualified tax professional who reviewed the facts and concluded that Form 3520 was not required. Note that reliance must meet specific requirements: the advice must have been given by a competent professional, the taxpayer must have provided the adviser with all relevant information, and the taxpayer must have reasonably relied on the advice in good faith. Hedge to IRS.gov and applicable IRS guidance (including Rev. Proc. 2022-2 and any successor guidance) for the standard applicable to reliance claims.
• Circumstances beyond the taxpayer's control that prevented timely filing, such as a natural disaster, serious illness, or other extraordinary circumstances, with evidence that the taxpayer acted promptly once the circumstances allowed.

The overarching standard is whether the taxpayer exercised ordinary business care and prudence with respect to the filing obligation. Hedge all specifics of the reasonable cause standard to current IRS guidance and IRS.gov.

Reliance on a Tax Professional Alone May Not Be Sufficient

The IRS has taken the position in multiple cases, and courts have affirmed, that mere reliance on a tax professional does not automatically constitute reasonable cause for failing to file an international information return. The taxpayer must demonstrate that the reliance was reasonable given all the facts, that the adviser was actually qualified to advise on the specific issue, and that the taxpayer provided the adviser with all relevant information. A practitioner who did not know about the foreign trust or foreign gift because the client did not disclose it cannot provide the basis for a reasonable cause defense; the client's failure to disclose is itself a fact that undercuts the reasonableness of the reliance.

The IRS Penalty Abatement Unit for International Information Returns

The IRS has a dedicated penalty abatement unit that handles reasonable cause requests for international information return penalties, including IRC 6677 penalties. A written statement explaining the circumstances must be submitted with the request. The IRS may send additional information requests before making a determination. The process can be lengthy, and there is no guarantee of abatement even with a well-documented request. Hedge the procedure to current IRS.gov guidance for the abatement process.

First-Time Abatement Does Not Apply

The IRS first-time abatement (FTA) administrative waiver, which provides automatic relief for certain failure-to-file and failure-to-pay penalties for taxpayers with a clean compliance history, does NOT apply to penalties under IRC 6677. This is a critical distinction that practitioners must communicate clearly to clients who have benefited from FTA relief in other contexts and assume it will apply here as well. Form 3520 and Form 3520-A penalties require a separate, independent showing of reasonable cause and not willful neglect. There is no FTA shortcut.

Section 7: Proposed Regulations (May 2024) -- What Is Pending

In May 2024, the IRS published proposed regulations under IRC 6048 and related provisions of the Code that would revise the reporting requirements for foreign trusts and gifts. As of July 2026, these regulations have NOT been finalized. Practitioners must apply the existing rules and should NOT advise clients based on the proposed regulations as if they were already in effect.

Current Operative Rules

The operative rules for Form 3520 and Form 3520-A reporting as of July 2026 are:

• The existing temporary regulations under Temp. Reg. 1.6048-1 through 1.6048-4 (and any related provisions).
• The December 2025 updated Form 3520 and Form 3520-A instructions, which represent the current IRS operational guidance for all line-level requirements.

What the Proposed Regulations Would Change (If Finalized)

The May 2024 proposed regulations would, if finalized, address certain reporting gaps, clarify the definition of "foreign trust" for reporting purposes, and modify certain threshold amounts and reporting obligations. Practitioners should monitor IRS.gov for any finalization notice, as the proposed regulations (or a modified version) could change the reporting obligations that apply to clients. All specifics of the proposed regulations must be verified against the text of the proposed regulations as published in the Federal Register and confirmed at IRS.gov; this guide does not attempt to summarize all proposed changes in detail, as they are subject to revision before any finalization.

Under no circumstances should a practitioner advise a client that the proposed regulations govern their current filing obligations. The proposed regulations are a signal of future direction; they are not law until finalized and effective.

December 2025 Updated Instructions: Separate from the Proposed Regulations

The December 2025 updated Form 3520 and Form 3520-A instructions are a separate development from the proposed regulations. The updated instructions represent the IRS's current administrative guidance under the existing regulatory framework. They are effective and must be used for current filings. The proposed regulations, by contrast, remain pending. Practitioners should use the December 2025 instructions for current compliance while monitoring IRS.gov for any finalization of the proposed regulations.

Section 8: Foreign Gift vs. Foreign Inheritance -- Income Tax and Reporting

A recurring source of confusion for clients (and sometimes for practitioners who are primarily domestic-focused) is the distinction between the income tax treatment of a foreign gift or inheritance and the Form 3520 reporting obligation. These two matters are governed by entirely separate legal frameworks and do not affect each other.

Foreign Gifts: Not Taxable Income, But Still Reportable

Under IRC 102(a), amounts received as gifts, bequests, devises, or inheritances are excluded from the gross income of the recipient. A U.S. person who receives a $5 million gift from a nonresident alien parent owes no federal income tax on the receipt of that gift. The gift is not compensation, it is not business income, and it is not a taxable distribution from a trust (assuming it is received from an individual, not from a foreign trust). The income tax treatment is straightforward: the gift is excluded from gross income.

However, if the gift from that nonresident alien parent exceeds the applicable reporting threshold under IRC 6039F (confirmed at IRS.gov and current Form 3520 instructions), the U.S. person must file Form 3520. The filing obligation exists regardless of the income tax treatment. The IRC 6677 penalty for failure to file does not depend on any income tax owed; it is calculated against the gross value of the unreported gift.

Foreign Bequests and Inheritances

A bequest from a foreign decedent's estate is treated similarly to a gift for income tax purposes: generally excluded from gross income under IRC 102(a). However, the Form 3520 reporting obligation under IRC 6039F applies to bequests just as it applies to inter vivos gifts, if the amount received exceeds the applicable threshold (confirmed at IRS.gov).

On the estate tax side, whether a bequest from a foreign decedent's estate is subject to U.S. estate tax depends on the decedent's domicile at death and any applicable estate or gift tax treaty between the United States and the decedent's country. A nonresident alien decedent is generally subject to U.S. estate tax only on U.S.-situs assets; the estate tax analysis is separate from the Form 3520 reporting obligation and requires independent analysis. Practitioners must address both the Form 3520 reporting obligation and any estate tax treaty considerations as distinct matters.

Separately, U.S. donors who make gifts to U.S. persons through foreign entities or structures may also encounter domestic gift tax reporting obligations under Form 709. If a foreign gift involves parties or structures that could trigger domestic gift tax analysis, see the Form 709 gift tax return, gift splitting, and GST allocation practitioner guide for domestic gift tax reporting requirements.

The Key Distinction: Reporting Obligation vs. Tax Liability

The core message for clients: the absence of income tax on a foreign gift or bequest does NOT eliminate the Form 3520 reporting obligation. These are two completely separate requirements governed by different sections of the Code (IRC 102 for income exclusion; IRC 6039F and IRC 6048 for reporting; IRC 6677 for penalties). A client who receives a large foreign inheritance, correctly understands that it is not taxable income, and then concludes that no forms are needed is at serious risk of the full IRC 6677 penalty. Every client who receives a gift or bequest from a foreign person should be asked, without exception, about the amount received and whether it may exceed the reporting thresholds for their category of donor.

Frequently Asked Questions

Common questions from enrolled agents, CPAs, and tax attorneys advising clients with foreign trust and foreign gift reporting obligations.

Related Practitioner Guides

The following guides cover international information reporting obligations and domestic gift tax matters that intersect with Form 3520 and Form 3520-A compliance.

• IRC 7701(b): Substantial Presence Test -- the residency determination that converts a foreign national into a U.S. resident subject to Form 3520 and 3520-A foreign trust reporting.
• IRC 6677: Foreign Trust Reporting Penalties -- the penalty structure for Forms 3520 and 3520-A failures: the 35% gross-value penalty, continuation escalations, and the reasonable cause defense.
• FBAR, FATCA, Form 114, and Form 8938 Foreign Information Reporting Practitioner Guide -- covers FinCEN Form 114 (FBAR) and Form 8938 (FATCA) reporting obligations for foreign financial accounts and specified foreign financial assets, including the relationship between FATCA data sharing and Form 3520 enforcement. Form 3520 and FBAR/FATCA are related but distinct obligations; this guide covers the overlap.
• Form 709 Gift Tax Return, Gift Splitting, and GST Allocation Practitioner Guide -- covers domestic gift tax reporting obligations under Form 709, including situations where a foreign gift may also trigger domestic gift tax analysis if structured through a U.S.-connected entity or if a U.S.-domiciled donor is involved.
• foreign tax credit Form 1116 and Form 1118 guide -- a foreign trust with investment income may generate both Form 3520-A reporting for the U.S. owner and foreign tax credit obligations on the underlying foreign-source income, so the Form 1116 limitation and the OBBBA basket rules frequently arise alongside the Form 3520 analysis.
• IRC 671-679: Grantor Trust Rules, IDGT, SLAT, and Income Inclusion -- practitioner guide to grantor trust deemed-owner attribution under IRC 671, IDGT triggering powers under IRC 675, SLAT spousal attribution under IRC 677, and the IRC 679 foreign grantor trust deemed-owner rule -- directly relevant to U.S. owners of foreign grantor trusts deemed to hold trust assets under IRC 679.
• IRC 6048 foreign trust reporting requirements -- the three separate reporting obligations for foreign trust creation, ownership, and distributions that Form 3520 and Form 3520-A carry out, including the 2024 proposed regulations and coordination with FBAR and FATCA.

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