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Form 3520-A

Form 3520-A: Deadline and Extension


Form 3520-A is a crucial aspect of tax compliance for U.S. persons with interests in foreign trusts. This form, formally known as the Annual Information Return of Foreign Trust with a U.S. Owner, serves to provide the IRS with necessary information regarding foreign trusts, their U.S. beneficiaries, and U.S. persons who are considered owners under the grantor trust rules (Sections 671 through 679 of the Internal Revenue Code).

The complexities of international tax law necessitate a thorough understanding of Form 3520-A’s requirements, deadlines and extension processes to ensure compliance and avoid substantial penalties. For individuals and entities dealing with foreign trusts, being well-informed about these obligations is not merely beneficial—it is essential. Dimov Tax & CPA Services is committed to guiding clients through these requirements, providing expert assistance to ensure that all forms are correctly filed and submitted on time.

Form 3520-A

Form 3520-A, Annual Information Return of Foreign Trust with a U.S. Owner, is an essential document required by the IRS for any foreign trust with at least one U.S. owner. It provides detailed information about the foreign trust, its U.S. beneficiaries, and any U.S. person treated as an owner under the grantor trust rules (Sections 671 through 679 of the Internal Revenue Code)​​.


A foreign trust with a U.S. owner is obligated to file Form 3520-A. The U.S. owner must ensure that the form is filed accurately and timely. If the foreign trust fails to file, the U.S. owner must complete and attach a substitute Form 3520-A to their Form 3520 to avoid penalties​​.


Form 3520-A must be filed by the 15th day of the third month after the end of the trust’s tax year. This means that if a foreign trust’s tax year ends on December 31, the filing deadline for Form 3520-A is March 15 of the following year. This deadline ensures that the IRS receives timely information about foreign trusts with U.S. owners, which is critical for tax compliance and enforcement​.

Example of Filing Deadlines

  • Trust’s Tax Year Ends on December 31: Form 3520-A is due by March 15 of the following year.
  • Trust’s Tax Year Ends on June 30: Form 3520-A is due by September 15 of the same year.

It is essential to note that this deadline is distinct from the deadlines for other tax forms that a U.S. owner might need to file. The specific timing reflects the need for the IRS to integrate foreign trust information with other tax filings promptly.

Extension Options for Form 3520-A

In certain circumstances, it is possible to request an extension for filing Form 3520-A. This is done by filing Form 7004, Application for Automatic Extension of Time to File Certain Business Income Tax, Information, and Other Returns. This form must be submitted to the IRS by the original due date of Form 3520-A​​.

Steps to Request an Extension

  1. Ensure the Foreign Trust Has an EIN: Before filing Form 7004, the foreign trust must have an Employer Identification Number (EIN). This number is used to identify the trust in IRS records.
  2. Complete Form 7004: This form requests an automatic extension for various business-related returns, including Form 3520-A. It is essential to fill out the form accurately and completely.
  3. Submit Form 7004 to the IRS: The form should be filed with the IRS by the original due date of Form 3520-A (e.g., March 15 for a calendar year trust). Filing Form 7004 grants an automatic six-month extension for filing Form 3520-A, moving the deadline to September 15 for a calendar year trust​​.
  4. Verify Extension Confirmation: After submitting Form 7004, it is advisable to verify that the IRS has granted the extension. This can be done by checking IRS records or contacting the IRS if confirmation has not been received within a reasonable period.

Limitations and Considerations

  • Extension for Form 3520: An extension for filing an income tax return (e.g., Form 1040) does not automatically extend the deadline for Form 3520-A. Separate extensions must be requested.
  • No Further Extensions: The extension granted by Form 7004 is typically the maximum extension allowed. There are no additional extensions beyond this period.
  • Late Filing Penalties: Failing to file Form 3520-A on time, without an approved extension, can result in significant penalties. These penalties underscore the importance of adhering to filing deadlines or properly requesting an extension​​.

Consequences of Missing Deadlines

Missing the filing deadline for Form 3520-A, without securing an extension, can lead to severe penalties. According to the IRS, the penalty for failing to file Form 3520-A is the greater of $10,000 or 5% of the gross value of the trust’s assets treated as owned by the U.S. person at the close of the tax year. This penalty structure is designed to encourage timely and accurate reporting of foreign trust information​​.

Practical Tips for Compliance

  • Mark Key Dates: Ensure that all key dates for filing Form 3520-A and requesting extensions are clearly marked and monitored.
  • Use Professional Services: Consider employing professional tax services to handle the complexities of international tax filings.
  • Maintain Comprehensive Records: Keeping detailed and accurate records of all transactions and filings related to the foreign trust can help ensure compliance and facilitate any necessary extensions.

By understanding the deadlines and extension options for Form 3520-A, U.S. owners of foreign trusts can better manage their tax obligations and avoid costly penalties. Dimov Tax & CPA Services is available to provide expert guidance and support throughout this process, ensuring that all requirements are met efficiently and accurately.

Services Provided by Dimov Tax & CPA Services

Dimov Tax & CPA Services offers comprehensive support for all matters related to Form 3520-A, including:

  • Filing Assistance: Ensuring accurate and timely filing of Form 3520-A and Form 7004.
  • Substitute Filing: Assisting with the preparation of substitute Form 3520-A if the foreign trust fails to file.
  • Compliance Review: Reviewing foreign trust documents to ensure compliance with IRS regulations.
  • Penalty Abatement: Assisting in penalty abatement requests if there are reasonable causes for late filing.


Form 3520-A is essential for U.S. owners of foreign trusts to avoid penalties and stay compliant with IRS regulations. Dimov Tax & CPA Services is dedicated to providing expert guidance and support to ensure all filing requirements are met. Contact us for professional assistance with your foreign trust reporting obligations.

By following these guidelines and leveraging our expertise, you can ensure compliance and avoid the pitfalls associated with foreign trust reporting.

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