Interested in training for your team? Click here to learn more

Foreign Trust and Gift Reporting: Proposed Regulations, Legislative History, Practical Implications

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Tuesday, February 11, 2025

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, January 17, 2025

or call 1-800-926-7926
Add to your calendar

This webinar will provide an overview of the legislative history affecting taxpayers with foreign trusts and receiving certain foreign gifts. Our panel of international tax advisers will review the recent proposed regulations, discuss Form 3520 and 3520A reporting requirements, and provide practical advice for applying these rules and avoiding penalties.

Description

IRC Section 6048 contains strict reporting requirements to address concerns that U.S. taxpayers avoid taxation by implementing foreign trusts. Satisfying these requirements includes reporting certain transactions on Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Historically, the IRS has assessed steep systematic reporting penalties for failure to report these transactions.

In May 2024, the IRS and Treasury released proposed regulations covering foreign gift and trust transactions. As is often the case, the release has generated questions on the application of these guidelines. The newly released regulations are similar to the rules in Notice 97-34 for reporting foreign gifts. They outline the requirements to establish foreign residency to avoid U.S. reporting requirements. Tax practitioners and taxpayers with dual residency status, foreign retirement plans, or receiving gifts from outside the U.S. must grasp the implications of recent guidelines impacting certain foreign transactions.

Listen as our panel of foreign gift reporting experts explains recent legislative developments impacting foreign trust and gift reporting.

READ MORE

Outline

  1. Recent developments in foreign trust and gift reporting
  2. Form 3520 and 3520A reporting requirements
  3. Foreign retirement plans
  4. Legislative history
    1. Notice 97-34
    2. Revenue Procedures 2014-55
    3. Revenue Procedure 2020-17
    4. Proposed regulations (REG-124850-08)
    5. Other guidelines
  5. IRS enforcement campaign
  6. Applicable penalties
  7. Practical implications

Benefits

The panel will cover these and other critical issues:

  • Comparing Revenue Procedure 2020-17 and the newly proposed regulations
  • The current state of IRS enforcement of reporting requirements under IRC Section 6048
  • Reporting guidelines for reporting foreign retirement plans
  • The legislative history surrounding reporting foreign trust and gift transactions

Faculty

Kennedy-C. Edward
C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing...  |  Read More

McGowin, Alex
Alex McGowin, CPA
International Tax Accountant
McGowin Tax

Mr. McGowin is a trusted advisor to multinational individuals and businesses seeking to optimize their global tax...  |  Read More

Attend on February 11

Early Discount (through 01/17/25)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

Cannot Attend February 11?

Early Discount (through 01/17/25)

CPE credit is not available on downloads.

CPE On-Demand

See NASBA details.