Foreign Trust & Form 3520 Compliance
Avoid penalties. Regain compliance. Protect your wealth.
Late Form 3520 Filings Carry Serious Penalties
If you’ve received a notice from the IRS related to a late or missing Form 3520 filing — or if you’ve just discovered that a filing was required — you’re not alone. Clients often find themselves in this situation due to incomplete advice, uncoordinated advisors, or misunderstandings about what a “foreign trust” actually is under U.S. law.
The penalties for a late Form 3520 can be staggering — starting at $10,000 and increasing to 35% of the value of trust distributions or contributions. These penalties are automatically assessed and difficult to reverse without a well-crafted legal response.
That’s where Sollertis comes in.
We Are Experts in Late 3520 Filings
Sollertis attorneys have successfully handled dozens of late 3520 filings for high-net-worth clients, often achieving full penalty abatement or substantial reductions. We understand both the legal and tax dimensions of Form 3520, and we know how to structure a compelling reasonable cause statement that gives the IRS a basis to waive penalties.
Whether the trust involves foreign grantors, international trustees, or U.S. beneficiaries receiving cross-border distributions — we have seen it before, and we know how to fix it.
Why Clients and Advisors Turn to Sollertis
- Experienced Legal Counsel: We don’t just prepare the form — we defend the filing position and stand behind the strategy.
- Penalty Relief Strategy: We craft persuasive, customized reasonable cause statements backed by legal precedent.
- Advisor Coordination: We work closely with CPAs and other professionals to ensure filings are accurate, timely, and consistent with broader tax strategy.
- Discreet, High-Level Support: We often assist when existing advisors are unsure how to proceed — and always respect existing relationships.
Who We Help
- U.S. persons with foreign trusts, especially discretionary or asset protection trusts
- Clients unaware they had a 3520 filing requirement until after the deadline
- CPA firms seeking legal support for complex 3520 filings or penalty resolution
- Families managing international gifting or distributions through offshore entities
Beyond the Form: Planning for the Future
While many clients come to us for help with a single 3520 issue, that work often reveals an opportunity to better align their overall tax and asset protection strategy with their long-term goals.
Need Help with a Late 3520 Filing?
Contact us today for a confidential consultation. Whether you’re a client, an advisor, or both — we’re here to help you resolve the issue and move forward with confidence.
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