Form 3520 Penalties (In Under 10 Minutes) - Overview of the 3520 Penalty Process & Common Defenses

www.goldinglaw...
Form 3520 Penalty Explained
A U.S. taxpayer may have to file many different international information reporting forms each year to disclose their foreign accounts, assets, investments, businesses, gifts, and trusts to the IRS. One of the most common types of international information reporting forms that Taxpayers are required to file (especially for those with family members overseas) is IRS Form 3520 - which is used to report foreign gifts and trusts. Our International Tax Lawyers have represented many Taxpayers across the globe with Form 3520 issues. When it comes to late Form 3520 filing and penalties, it is always crucial to assess each Taxpayer’s specific facts and circumstances - along with strategizing the response and post-response objectives - before any submission is made to the IRS. While a Form 3520 CP15 Notice Response is time-sensitive, Taxpayers (and their counsel) should still be sure to have their ducks in a row before submitting their response. Some key issues to consider before submitting the CP15 Penalty Notice response are:
-Can the Taxpayer endure a multi-year penalty challenge process with the IRS?
-Is the Taxpayer willing to risk receiving a Notice of Federal Tax Lien?
-Is paying the penalty and challenging the IRS in Federal Court a viable option?
-Is the Taxpayer worried about a Notice of Levy being submitted to their employer?
-Are there potentially more Form 3520 penalties coming down the pipeline for other years?