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Issue 41230

Foreign Trusts IRS Penalty Notices For Late Forms

Issue Statement:

IRS instructions are unclear regarding the due date of substitute Form 3520-A. As a result taxpayers are being charged penalties for failure to file.

Goal Statement:

To correct IRS instructions to clarify the due date of substitute Form 3520-A.

RECOMMENDATION 0000

RECOMMENDATION TEXT:

Correct both:

(1) the instructions for Form 3520, and

(2) the instructions for Form 3520-A

to make the due date of substitute Form 3520-A clear

IRS Action: Monitoring IRS Action

We will adopt the suggestion to clarify the due date for filing a substitute Form 3520-A in the Instructions for Form 3520 and the Instructions for Form 3520-A.

current report

2023 TAP Annual Report

The six core project committees submitted 31 referrals to the IRS for consideration during the 2023 TAP year. These referrals contained 531 recommendations to the IRS.

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