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What is Form 3520-A and when does a foreign trust require it?

Form 3520-A is the annual information return for a foreign trust that has a U.S. owner under the grantor-trust rules. If you're treated as the owner of a foreign trust, that trust is expected to file Form 3520-A each year reporting its income, assets, and distributions, and to provide you a statement. In practice many foreign trusts won't file it themselves, so the U.S. owner often has to file a substitute 3520-A to avoid penalties — and separately report on Form 3520. This catches people with overseas family trusts or certain foreign retirement and savings arrangements that the IRS classifies as trusts. The deadline is generally the 15th day of the third month after the trust's year-end, earlier than your personal return. Penalties are significant. If you're connected to any structure called a 'trust' abroad, get a specialist to determine your filing obligations early.

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