U.S. Tax Alert: IRS Provides Relief for Certain Foreign Trust Reporting. Rev. Proc. 2020-17 And What it Means to You

Who Will Benefit From Attending This Webinar?

This webinar is intended for U.S. citizens and residents with foreign trust or trust-like arrangements. The content is especially relevant to U.S. tax and Canadian tax advisors who are assisting their clients in addressing U.S. tax and cross-border implications.

 

Topics Covered in This Webinar.

U.S. citizens and Green card holders living in Canada often open TFSA and RESP accounts. The U.S. tax treatment of these accounts is uncertain in that some U.S. tax advisors are treating those accounts as foreign grantor trusts. As a result, two international information return filings were required: Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner and Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. The IRS relief is very timely and will help many U.S. citizens and Green card holders significantly reduce their tax return preparation and filing fees – a very positive development for taxpayers!

Our position has always been that these accounts should be treated as savings accounts and, provided that the income was properly and timely reported on U.S. tax return, as well as the proper disclosure of such accounts was made on Form FinCEN 114 (FBAR) and Form 8938 (FATCA form), as applicable, no reporting on Forms 3520 and 3520-A was required. The IRS has effectively concurred with our tax filing position.

 

Here’s just a sample of what we’ll cover during this webinar: 

• Review of Revenue Procedure 2020-17;
• Types of “foreign trusts” and arrangements/accounts covered by the IRS guidance;
• U.S. tax and reporting requirements applicable to foreign trusts and arrangements / accounts addressed in the IRS guidance;
• Passive Foreign Investment Company (PFIC) reporting;
• How do you claim your penalties for missed Form 3520-A/3520 reporting (if the IRS has assessed them and you may have paid them previously)?;
• Statute of limitations considerations;
• Penalty protection and taking aggressive tax return filing positions;
• Tax compliance tips and practical considerations;
• … and more!

 

To learn more, please register and gain the knowledge you need to help your clients claim their money back and relieve their 2019 tax year U.S. filings. Plus, you can earn up to 1 CPD credit (relevant to Canadian CPAs).  We hope you join us!