Law links and verification status · Blank forms. Citation links are generated from extracted text; unverified links, image-only pages and incomplete citations require review. Reference-book links open publisher resources, not exact definitions.

i3520

PDF page numbers count from the first file page; printed labels may differ.

Open document online · Download source file

Userid: CPM Schema: 
instrx
Leadpct: 100% Pt. size: 10  Draft  Ok to Print
AH XSL/XML Fileid: … orm-3520/202512/a/xml/cycle06/source (Init. & Date) _______
Page 1 of 15  15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Instructions for Form 3520
(Rev. December 2025)
(Use with December 2023 revision of Form 3520.)
Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain 
Foreign Gifts
Section references are to the Internal Revenue Code 
unless otherwise noted.
Future Developments
For the latest information about developments related to 
Form 3520 and its instructions, such as legislation 
enacted after they were published, go to IRS.gov/
Form3520.
What’s New
New guidance regarding the section 2801 tax. 
Section 2801 imposes a tax on U.S. citizens and residents 
who receive gifts or bequests from covered expatriates. 
For more information, see IRS.gov/Businesses/Gifts-
From-Foreign-Person.
Reminders
Due dates. Form 3520 is due by the 15th day of the 4th 
month following the end of the taxpayer’s tax year. 
However, taxpayers who live and work outside the United 
States have until the 15th day of the 6th month to file the 
form. If an extension has been requested, check box 1k 
and include the form number of the tax return for which the 
extension applies. See When and Where T o File, later.
Form 3520-A is due by the 15th day of the 3rd month 
after the end of the foreign trust’s tax year. However, a 
substitute Form 3520-A attached to a U.S. owner’s Form 
3520 is due the same day as Form 3520. The U.S. owner 
must check the “Substitute Form 3520-A” checkbox on the 
top of Form 3520-A that is attached to Form 3520. See 
Instructions for Form 3520-A.
Assessment period. If a complete Form 3520 is not filed 
by the due date, including extensions, the time for 
assessment of any tax imposed with respect to any event 
or period to which the information required to be reported 
in Parts I through III of such Form 3520 relates will not 
expire before the date that is 3 years after the date on 
which the required information is reported. See section 
6501(c)(8).
Continuous-use revision. Use these instructions for tax 
year 2025 and subsequent years until a superseding 
revision is issued.
General Instructions
Purpose of Form
U.S. persons (and executors of estates of U.S. decedents) 
file Form 3520 with the IRS to report:
• Certain transactions with foreign trusts,
• Ownership of foreign trusts under the rules of sections 
671 through 679, and
• Receipt of certain large gifts or bequests from certain 
foreign persons.
A separate Form 3520 must be filed for transactions 
with each foreign trust.
Who Must File
File Form 3520 if any one or more of the following apply.
1. Y ou are the responsible party for reporting a 
reportable event that occurred during the current tax year, 
or you are a U.S. person who transferred property 
(including cash) to a related foreign trust (or a person 
related to the trust) in exchange for an obligation or you 
hold a qualified obligation from that trust that is currently 
outstanding. For definitions, see Responsible Party, 
Reportable Event, Qualified Obligation, and Person 
related to a foreign trust, later.
Complete the identifying information on page 1 of the 
form and the relevant portions of Part I. See the 
instructions for Part I.
2. Y ou are a U.S. person who, during the current tax 
year, is treated as the owner of any part of the assets of a 
foreign trust under the rules of sections 671 through 679. 
U.S. person and owner are defined later.
Complete the identifying information on page 1 of the 
form and Part II. See the instructions for Part II.
Note: Y ou are required to complete Part II even if there 
have been no transactions involving the trust during the 
tax year. Y ou may also be required to complete a 
substitute Form 3520-A, Annual Information Return of 
Foreign T rust With a U.S. Owner, and attach it to your 
Form 3520. See Penalties, later.
3. Y ou are a U.S. person (including a U.S. owner) or an 
executor of the estate of a U.S. person who received, 
directly or indirectly, a distribution from a foreign trust 
during the current tax year; or you are a U.S. person who 
is a U.S. owner or beneficiary of a foreign trust and in the 
current tax year you or a U.S. person related to you 
received (1) a loan of cash or marketable securities 
(including an extension of credit) directly or indirectly from 
such foreign trust, or (2) the uncompensated use of trust 
property; or you are a U.S. person who is a U.S. owner or 
beneficiary of a foreign trust and in the current tax year 
such foreign trust holds an outstanding qualified obligation 
of yours or a U.S. person related to you. For definitions, 
see U.S. Person, Owner, Distribution, U.S. Beneficiary, 
and Related Person, later.
Instructions for Form 3520 (Rev. 12-2025)  Catalog Number 23068I
Oct 7, 2025 Department of the T reasury  Internal Revenue Service  www.irs.gov

Page 2 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Complete the identifying information on page 1 of the 
form and Part III. In the case of a U.S. person that is an 
estate, check “Executor” on line B on page 1. See the 
instructions for Part III.
4. Y ou are a U.S. person who, during the current tax 
year, received either:
a. More than $100,000 from a nonresident alien 
individual or a foreign estate (including foreign persons 
related to that nonresident alien individual or foreign 
estate) that you treated as gifts or bequests; or
b. More than the section 6039F threshold amount from 
foreign corporations or foreign partnerships (including 
foreign persons related to such foreign corporations or 
foreign partnerships) that you treated as gifts. The 
threshold amount is available at IRS.gov/
InflationAdjustment. Select the applicable tax year news 
release, then click on the Rev. Proc. link and search for 
section 6039F to see the threshold amount under Notice 
of Large Gifts Received from Foreign Persons.
Complete the identifying information on page 1 of the 
form and Part IV . See the instructions for Part IV.
Exceptions To Filing
Form 3520 does not have to be filed to report the following 
transactions.
• T ransfers to funded nonqualified deferred 
compensation arrangements described in section 402(b); 
stock bonuses, pensions, or profit-sharing trusts that 
would qualify for exemption under section 501(a) except 
for the fact that it is a trust created or organized outside 
the United States described in section 404(a)(4); and 
amounts paid or accrued by an employer under a qualified 
foreign plan described in section 404A.
• Most fair market value (FMV) transfers by a U.S. person 
to a foreign trust. However, some FMV transfers must 
nevertheless be reported on Form 3520 (for example, 
transfers in exchange for obligations that are treated as 
qualified obligations, transfers of appreciated property to a 
foreign trust for which the U.S. transferor does not 
immediately recognize all of the gain on the property 
transferred, and transfers involving a U.S. transferor that is 
related to the foreign trust). See section III of Notice 97-34, 
1997-25 I.R.B. 22, available at IRS.gov/pub/irs-irbs/
irb97-25.pdf.
• T ransfers to foreign trusts that have a current 
determination letter from the IRS recognizing their status 
as exempt from income taxation under section 501(c)(3).
• Deemed transfers from domestic trusts that become 
foreign trusts to the extent the trust is treated as owned by 
a foreign person, after application of section 672(f).
• Distributions from foreign trusts that are taxable as 
compensation for services rendered (within the meaning 
of section 672(f)(2)(B) and its regulations), so long as the 
recipient reports the distribution as compensation income 
on its applicable federal income tax return.
• Distributions from foreign trusts to domestic trusts that 
have a current determination letter from the IRS 
recognizing their status as exempt from income taxation 
under section 501(c)(3).
• T ransfers to, ownership of, and distributions from a 
Canadian registered retirement savings plan (RRSP), a 
Canadian registered retirement income fund (RRIF), or 
any other Canadian retirement plan that is within the 
meaning of section 3 of Rev. Proc. 2014-55. See Rev. 
Proc. 2014-55, 2014-44 I.R.B. 753, available at 
IRS.gov/IRB/2014-44_IRB#RP-2014-55.
• Certain eligible individuals’ transfers to, ownership of, 
and distributions from certain tax-favored foreign 
retirement trusts and certain tax-favored foreign 
nonretirement savings trusts, as described in section 5 of 
Rev. Proc. 2020-17. For more information about whether 
you are an eligible individual and whether your foreign 
trust qualifies for an exemption from foreign trust 
information reporting, see Rev. Proc. 2020-17, 2020-12 
I.R.B. 539, available at IRS.gov/IRB/2020-12_IRB#REV-
PROC-2020-17.
• Certain eligible individuals’ transactions with, and 
ownership of, certain tax-favored foreign trusts that are 
established and operated exclusively or almost exclusively 
to provide pension or retirement benefits, or to provide 
medical, disability, or educational benefits, as described in 
proposed regulations under section 6048. Y ou may rely on 
these proposed regulations for any tax year ending after 
May 8, 2024, and beginning on or before the date that final 
regulations are published in the Federal Register, 
provided you and all related persons (within the meaning 
of sections 267(b) and 707(b)(1)) apply the proposed 
regulations in their entirety and in a consistent manner for 
all tax years beginning with the first tax year of reliance 
until the applicability date of the final regulations. For more 
information on whether you are an eligible individual and 
whether your foreign trust qualifies for an exemption from 
foreign trust information reporting, see Proposed 
Regulations section 1.6048-5 as published in the Federal 
Register at govinfo.gov/content/pkg/FR-2024-05-08/pdf/
2024-09434.pdf.
The exemptions from foreign trust information reporting 
described in Rev. Proc. 2014-55, Rev. Proc. 2020-17, and 
the proposed regulations under section 6048 do not affect 
any other reporting obligations.
Joint Returns
If you and your spouse are filing a joint income tax return 
for the current tax year, and you are both transferors, 
grantors, or beneficiaries of the same foreign trust, then 
you may file a joint Form 3520 for the same tax year. If you 
and your spouse are filing a joint Form 3520, check the 
box on line 1i on page 1.
Additional Reporting and Tax 
Information
For more information on large gifts or bequests from 
foreign persons, go to IRS.gov/Businesses/Gifts-From-
Foreign-Person. For more information on foreign trust 
reporting requirements and tax consequences, go to 
IRS.gov/ForeignT rust.
Y ou may be required to file Financial Crimes 
Enforcement Network (FinCEN) Form 114, Report of 
Foreign Bank and Financial Accounts (FBAR). In addition, 
you may be required to file Form 8938, Statement of 
Specified Foreign Financial Assets. For more information, 
go to IRS.gov/FBAR.
2 Instructions for Form 3520 (Rev. 12-2025)

Page 3 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
When and Where To File
In general, a U.S person’s Form 3520 is due on the 15th 
day of the 4th month following the end of such person’s 
tax year for income tax purposes. For a calendar-year 
individual, this is generally the same day as the filer’s 
income tax return due date. If a U.S. person is granted an 
extension of time to file an income tax return, Form 3520 is 
due no later than the 15th day of the 10th month following 
the end of the U.S. person’s tax year.
Note: This may differ from and is not tied to the due date 
of the U.S. person’s income tax return.
If you are an individual who is a U.S. citizen or resident 
who satisfies one of the following conditions on the due 
date of your income tax return, then the due date for filing 
Form 3520 is extended from the 15th day of the 4th month 
(April 15) to the 15th day of the 6th month (June 15) 
following the end of your tax year. Y ou must include a 
statement with Form 3520 showing that you are a U.S. 
citizen or resident who meets one of these conditions.
• Y ou live outside of the United States and Puerto Rico 
and your place of business or post of duty is outside the 
United States and Puerto Rico.
• Y ou are in the military or naval service on duty outside 
the United States and Puerto Rico.
If you are an individual who is a U.S. citizen or resident 
and are granted an extension of time to file your income 
tax return, the due date for filing Form 3520 is no later than 
the 15th day of the 10th month (October 15) following the 
end of your tax year.
If you are filing a Form 3520 for a U.S. decedent, the 
due date is the 15th day of the 4th month (April 15) 
following the end of the decedent’s last tax year for 
income tax purposes. If the U.S. decedent is granted an 
extension of time to file their income tax return, then the 
due date for filing Form 3520 is no later than the 15th day 
of the 10th month (October 15) following the end of 
decedent’s last tax year.
If you are filing a Form 3520 for a U.S. decedent’s 
estate, the due date is the 15th day of the 4th month 
following the end of the estate’s tax year for income tax 
purposes. If the U.S. decedent’s estate is granted an 
extension of time to file its income tax return, then the due 
date for filing Form 3520 is no later than the 15th day of 
the 10th month following the end of the estate’s tax year.
If you are the U.S. owner of a foreign trust, the due date 
for filing a substitute Form 3520-A is the due date of your 
Form 3520. Y ou must attach the substitute Form 3520-A, 
including the Foreign Grantor T rust Owner Statement and 
the Foreign Grantor T rust Beneficiary Statement, to your 
Form 3520. Y ou must also provide copies of the Foreign 
Grantor T rust Owner Statement and the Foreign Grantor 
T rust Beneficiary Statement to the U.S. owners and U.S. 
beneficiaries by the due date of your Form 3520. See the 
Instructions for Form 3520-A.
If the due date falls on a Saturday, Sunday, or legal 
holiday, file by the next day that is not a Saturday, Sunday, 
or legal holiday.
Send Form 3520 to the following address.
Internal Revenue Service Center
P .O. Box 409101
Ogden, UT 84409
Only a complete Form 3520 is considered timely filed. 
Form 3520 is considered complete only if all required 
attachments are included.
Caution: If a complete Form 3520 is not filed by the due 
date, including extensions, the time for assessment of any 
tax imposed with respect to any event or period to which 
the information required to be reported in Parts I through III 
as it relates to Form 3520 will not expire before the date 
that is 3 years after the date on which the required 
information is reported. See section 6501(c)(8).
Who Must Sign
If Form 3520 is filed by:
• An individual or a fiduciary, it must be signed and dated 
by that individual or fiduciary;
• A partnership, it must be signed and dated by a partner 
or limited liability company member;
• A corporation, it must be signed and dated by the 
president, vice president, treasurer, assistant treasurer, 
chief accounting officer, or any other corporate officer who 
is authorized to sign; or
• A receiver, trustee, or assignee filing on behalf of a 
partnership or corporation, it must be signed and dated by 
the fiduciary. A Form 3520 signed by a receiver or trustee 
in bankruptcy on behalf of a partnership or corporation 
must be accompanied by a copy of the order or 
instructions of the court authorizing signing of Form 3520.
A substitute Form 3520-A attached to the U.S. owner’s 
Form 3520 must be signed and dated by the U.S. owner. 
The U.S. owner’s name and taxpayer identification 
number (TIN) must be provided on the “Title” line of the 
signature box. See the Instructions for Form 3520-A.
Note: E-signatures are accepted.
When using a paid preparer, the paid preparer must do 
the following.
• Complete the required preparer information at the 
bottom of page 6, including their name, Preparer T ax 
Identification Number (PTIN), and other identifying details.
• Sign the return in the space provided for the preparer’s 
signature.
• Provide a copy of the return to the filer.
Inconsistent Treatment of Items
The U.S. beneficiary’s and U.S. owner’s tax returns must 
be consistent with the Form 3520-A filed by the foreign 
trust unless you report the inconsistency to the IRS. If you 
are treating items on your tax return differently from the 
way the foreign trust treated them on its return, file Form 
8082, Notice of Inconsistent T reatment or Administrative 
Adjustment Request (AAR). See Form 8082 for more 
details.
Penalties
Section 6677. A penalty applies if Form 3520 is not 
timely filed or if the information is incomplete or incorrect. 
For exceptions, see Reasonable cause, later. Generally, 
Instructions for Form 3520 (Rev. 12-2025) 3

Page 4 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
the initial penalty is equal to the greater of $10,000 or the 
following (as applicable).
• 35% of the gross value of any property transferred to a 
foreign trust for failure by a U.S. transferor to report the 
creation of or transfer to a foreign trust in Part I.
• 35% of the gross value of the distributions received 
from a foreign trust for failure by a U.S. person to report 
receipt of the distribution in Part III.
• 5% of the gross value of the portion of the foreign trust’s 
assets treated as owned by a U.S. person under the 
grantor trust rules (sections 671 through 679), if the 
foreign trust (a) fails to file a timely Form 3520-A and 
furnish the required annual statements to its U.S. owners 
and U.S. beneficiaries; or (b) does not furnish all of the 
information required by section 6048(b) or includes 
incorrect information. See section 6677(a) through (c) and 
the instructions for Part II of this form and Form 3520-A.
If a foreign trust fails to file Form 3520-A, the U.S. 
owner must complete and attach a substitute Form 
3520-A to the U.S. owner’s Form 3520 by the due date of 
the U.S. owner’s Form 3520 (and not the due date for the 
Form 3520-A, which is otherwise due by the 15th day of 
the 3rd month after the end of the trust’s tax year) in order 
to avoid being subject to the penalty for the foreign trust’s 
failure to timely file Form 3520-A. For example, a 
substitute Form 3520-A that, to the best of the U.S. 
owner’s ability, is completed and attached to the U.S. 
owner’s Form 3520 by the due date for the Form 3520 
(such as April 15 for U.S. owners who are individuals), is 
considered to be timely filed.
Additional penalties will be imposed if the 
noncompliance continues for more than 90 days after the 
IRS mails a notice of failure to comply with the required 
reporting. If the IRS can determine the gross reportable 
amount (defined later), then the penalties will be reduced 
as necessary to assure that the aggregate amount of such 
penalties does not exceed the gross reportable amount. 
For more information, see section 6677.
Reasonable cause. No penalties will be imposed if the 
taxpayer can demonstrate that the failure to comply was 
due to reasonable cause and not willful neglect.
Note: The fact that a foreign country would impose 
penalties for disclosing the required information is not 
reasonable cause. See section 6677(d). Similarly, 
reluctance on the part of a foreign fiduciary or provisions 
in the trust instrument that prevent the disclosure of 
required information is not reasonable cause.
Section 6039F . In the case of a failure to timely report 
foreign gifts described in section 6039F , the IRS may 
determine the income tax consequences of the receipt of 
such gift, and a penalty equal to 5% of the amount of such 
foreign gifts applies for each month for which the failure to 
report continues (not to exceed a total of 25%). See 
section 6039F for additional information.
Reasonable cause. No penalty will be imposed if the 
taxpayer can demonstrate that the failure to comply was 
due to reasonable cause and not willful neglect.
Section 6662(j). If a U.S. owner of a foreign trust is 
subject to a 20% penalty imposed under section 6662 for 
an underpayment of tax required to be shown on a return, 
then such penalty may be increased to 40% under section 
6662(j) for any portion of an underpayment that is 
attributable to any transaction involving any asset with 
respect to which information was required to be provided 
on Form 3520-A. For more information about undisclosed 
foreign financial asset understatements, see section 
6662(j).
Reasonable cause. No penalty will be imposed with 
respect to any portion of an underpayment if the taxpayer 
can demonstrate that the failure to comply was due to 
reasonable cause with respect to such portion of the 
underpayment and the taxpayer acted in good faith with 
respect to such portion of the underpayment. See section 
6664(c) for additional information.
Definitions
Distribution
A distribution received directly or indirectly from a foreign 
trust for section 6048(c) reporting purposes is any 
gratuitous transfer of money or other property from a 
foreign trust, whether or not a portion of such trust is 
treated as a grantor trust under the grantor trust rules of 
sections 671 through 679, and without regard to whether 
the recipient is designated as a beneficiary by the terms of 
the trust. A distribution includes the receipt of a trust 
corpus and the receipt of a gift or bequest described in 
section 663(a).
A distribution also includes constructive transfers from 
a foreign trust. For example, if charges you make on a 
credit card are paid by a foreign trust or guaranteed or 
secured by the assets of a foreign trust, the amount 
charged will be treated as a distribution to you by the 
foreign trust. Similarly, if you write checks on a foreign 
trust’s bank account, the amount will be treated as a 
distribution. Also, if you receive a payment from a foreign 
trust in exchange for property transferred to the trust or 
services rendered to the trust, and the FMV of the 
payment you received exceeds the FMV of the property 
transferred or services rendered, the excess will be 
treated as a distribution to you. See section V of Notice 
97-34.
Examples. 
1. If you sell stock with an FMV of $100 to a foreign 
trust and receive $150 in exchange, you have received a 
distribution of $50.
2. If you receive $100 from a foreign trust for 
performing services for the trust, and the services have an 
FMV of $20, you have received a distribution of $80.
If you are a grantor or beneficiary of a foreign trust and 
you (or a U.S. person related to you) directly or indirectly 
received a loan of cash or marketable securities from a 
foreign trust, or you (or a U.S. person related to you) used 
any property owned by a foreign trust without paying FMV 
within a reasonable amount of time, the amount of such 
loan or the FMV of the use of trust property will be treated 
as a distribution for reporting purposes. For this purpose, 
a loan by an unrelated third party that is guaranteed by a 
foreign trust is generally treated as a loan from the trust. 
See section V .A of Notice 97-34.
Foreign Trust and Domestic Trust
A foreign trust is any trust other than a domestic trust.
4 Instructions for Form 3520 (Rev. 12-2025)

Page 5 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
A domestic trust is any trust if:
1. A court within the United States is able to exercise 
primary supervision over the administration of the trust, 
and
2. One or more U.S. persons have the authority to 
control all substantial decisions of the trust.
Grantor
A grantor includes any person who creates a trust or 
directly or indirectly makes a gratuitous transfer of cash or 
other property to a trust. A grantor includes any person 
treated as the owner of any part of a foreign trust’s assets 
under sections 671 through 679, excluding section 678.
Note: If a partnership or corporation makes a gratuitous 
transfer to a trust, the partners or shareholders are 
generally treated as the grantors of the trust, unless the 
partnership or corporation made the transfer for a 
business purpose of the partnership or corporation.
If a trust makes a gratuitous transfer to another trust, 
the grantor of the transferor trust is treated as the grantor 
of the transferee trust, except that if a person with a 
general power of appointment over the transferor trust 
exercises that power in favor of another trust, such person 
is treated as the grantor of the transferee trust, even if the 
grantor of the transferor trust is treated as the owner of the 
transferor trust.
Grantor Trust
A grantor trust is any trust to the extent that the assets of 
the trust are treated as owned by a person other than the 
trust. See the grantor trust rules in sections 671 through 
679. A part of the trust may be treated as a grantor trust to 
the extent that only a portion of the trust assets are owned 
by a person other than the trust.
Note: Under the HIRE Act, effective after March 18, 2010, 
if a foreign trust directly or indirectly loans cash or 
marketable securities to a U.S. person who does not repay 
the loan at a market rate of interest, or allows a U.S. 
person to use trust property without paying FMV within a 
reasonable period of time, the trust will be treated as 
having a U.S. beneficiary and therefore is treated as a 
grantor trust under the grantor trust rules. See section 
679.
Reporting by U.S. owners receiving distributions 
from foreign grantor trust. If a U.S. owner (defined 
later) of a foreign trust receives, directly or indirectly, a 
distribution from the foreign trust, the U.S. owner must 
only complete lines 24 and 27 in Part III.
Gratuitous Transfer
A gratuitous transfer to a foreign trust is any transfer to the 
trust other than (a) a transfer for FMV; or (b) a distribution 
to the trust with respect to an interest held by the trust (i) in 
an entity other than a trust (for example, a corporation or a 
partnership), or (ii) in an investment trust described in 
Regulations section 301.7701-4(c), a liquidating trust 
described in Regulations section 301.7701-4(d), or an 
environmental remediation trust described in Regulations 
section 301.7701-4(e). A gratuitous transfer includes any 
indirect transfer that is structured with a principal purpose 
of avoiding the application of section 679 or 6048.
A transfer of property to a trust may be considered a 
gratuitous transfer without regard to whether the transfer is 
a gift for gift tax purposes. See chapter 12 of subtitle B of 
the Code (that is, sections 2501 through 2524).
For purposes of this determination, if a U.S. person 
contributes property to a trust in exchange for any type of 
interest in the trust, such interest in the trust will be 
disregarded in determining whether FMV has been 
received. In addition, a U.S. person will not be treated as 
making a transfer for FMV merely because the transferor 
is deemed to recognize gain on the transaction.
If you transfer property to a related foreign trust in 
exchange for an obligation of the trust (or an obligation of 
a person related to the trust), it will be a gratuitous transfer 
unless the obligation is a qualified obligation. Any transfer 
in exchange for an obligation (whether or not a qualified 
obligation) must be reported under section 6048(a). For 
definitions, see Obligation and Qualified Obligation, later. 
See section III.B of Notice 97-34, and the regulations 
under sections 679 and 684 for additional information.
Gross Reportable Amount
Gross reportable amount is:
• The gross value of property involved in the creation of a 
foreign trust or the transfer of property to a foreign trust 
(including a transfer by reason of death);
• The gross value of any portion of a foreign trust treated 
as owned by a U.S. person under the rules of sections 671 
through 679 or any part of a foreign trust that is included in 
the gross estate of a U.S. citizen or resident;
• The gross value of the assets in a trust at the time the 
trust becomes a foreign trust, if the trust was a domestic 
trust to which a U.S. citizen or resident had previously 
transferred property, and provided that such U.S. citizen or 
resident is alive at the time the trust becomes a foreign 
trust (see section 679(a)(5)); or
• The gross amount of distributions received from a 
foreign trust.
Gross Value or Amount
For purposes of determining the gross reportable amount, 
the gross value or gross amount of property is the value of 
property as determined under section 2512 and its 
regulations, without regard to any prohibitions or 
restrictions on a person’s interest in the property. Although 
formal appraisals are not generally required, you should 
keep contemporaneous records of how you arrived at your 
good faith estimate.
Guarantee
A guarantee:
• Includes any arrangement under which a person, 
directly or indirectly, assures, on a conditional or 
unconditional basis, the payment of another’s obligation;
• Encompasses any form of credit support, and includes 
a commitment to make a capital contribution to the debtor 
or otherwise maintain its financial viability; or
• Includes an arrangement reflected in a “comfort letter,” 
regardless of whether the arrangement gives rise to a 
legally enforceable obligation. If an arrangement is 
Instructions for Form 3520 (Rev. 12-2025) 5

Page 6 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
contingent upon the occurrence of an event, in 
determining whether the arrangement is a guarantee, you 
must assume that the event has occurred.
Nongrantor Trust
A nongrantor trust is any trust to the extent that the assets 
of the trust are not treated as owned by a person other 
than the trust under the grantor trust rules in sections 671 
through 679. Thus, a nongrantor trust is treated as a 
taxable entity. A trust may be treated as a nongrantor trust 
with respect to only a portion of the trust assets. See 
Grantor T rust, earlier.
Obligation
An obligation includes any bond, note, debenture, 
certificate, bill receivable, account receivable, note 
receivable, open account, or other evidence of 
indebtedness, and, to the extent not previously described, 
any annuity contract.
Owner
An owner of a foreign trust is the person that is treated as 
owning any of the assets of a foreign trust under the rules 
of sections 671 through 679.
Property
Property means any property, whether tangible or 
intangible, including cash.
Qualified Obligation
A qualified obligation, for purposes of this form, is any 
obligation only if:
1. The obligation is reduced to writing by an express 
written agreement;
2. The term of the obligation does not exceed 5 years 
(including options to renew and rollovers);
3. All payments on the obligation are denominated in 
U.S. dollars;
4. The yield to maturity of the obligation is not less 
than 100% of the applicable federal rate under section 
1274(d) for the day on which the obligation is issued and 
not greater than 130% of the applicable federal rate;
5. The U.S. person agrees to extend the period for 
assessment of any income or transfer tax attributable to 
the transfer and any consequential income tax changes 
for each year that the obligation is outstanding to a date 
not earlier than 3 years after the maturity date of the 
obligation, unless the maturity date of the obligation does 
not extend beyond the end of the U.S. person’s tax year 
and is paid within such period (this is done on Part I, 
Schedule A, line 12, and Part III, line 26, as applicable); 
and
6. The U.S. person reports the status of the obligation, 
including principal and interest payments, on Part I, 
Schedule C, line 19, and Part III, line 28, as applicable, for 
each year that the obligation is outstanding.
Related Person
A related person generally includes any person who is 
related to you for purposes of sections 267 and 707(b). 
This includes, but is not limited to:
• A member of your family—your brothers and sisters, 
half-brothers and half-sisters, spouse, ancestors (parents, 
grandparents, etc.), lineal descendants (children, 
grandchildren, etc.), and the spouses of any of these 
persons; or
• A corporation in which you, directly or indirectly, own 
more than 50% in value of the outstanding stock.
See section 643(i)(2)(B) and the regulations under 
sections 267 and 707(b).
Person related to a foreign trust. A person is related to 
a foreign trust if such person, without regard to the transfer 
at issue, is a grantor of the trust, a beneficiary of the trust, 
or is related to any grantor or beneficiary of the trust. See 
the definition of Related Person above.
Reportable Event
A reportable event includes the following.
1. The creation of a foreign trust by a U.S. person.
2. The transfer of any money or property, directly or 
indirectly, to a foreign trust by a U.S. person, including a 
transfer by reason of death. This includes transfers that 
are deemed to have occurred under sections 679(a)(4) 
and (5).
3. The death of a U.S. citizen or resident if:
• The decedent was treated as the owner of any portion 
of a foreign trust under the rules of sections 671 through 
679, or
• Any portion of a foreign trust was included in the gross 
estate of the decedent.
Responsible Party
Responsible party means:
• The grantor in the case of the creation of an inter vivos 
trust;
• The transferor, in the case of a reportable event 
(defined above) other than a transfer by reason of death; 
or
• The executor of the decedent’s estate in any other case 
(whether or not the executor is a U.S. person).
U.S. Agent
A U.S. agent is a U.S. person (defined later) that has a 
binding contract with a foreign trust that allows the U.S. 
person to act as the trust’s authorized U.S. agent in 
applying sections 7602, 7603, and 7604 with respect to:
• Any request by the IRS to examine records or produce 
testimony related to the proper U.S. tax treatment of 
amounts distributed, or required to be taken into account 
under the grantor trust rules, with respect to a foreign 
trust; or
• Any summons by the IRS for such records or testimony.
A U.S. grantor, a U.S. beneficiary, or a domestic 
corporation controlled by the grantor or beneficiary may 
act as a U.S. agent. However, a foreign trust will not be 
treated as having a U.S. agent unless the U.S. agent’s 
name, address, and TIN are entered on lines 3a through 
3g on page 1 of Form 3520. See T axpayer identification 
numbers (TINs), later.
If a foreign trust with a U.S. owner does not have a U.S. 
agent, the IRS may redetermine the amounts required to 
be taken into account with respect to the foreign trust by 
6 Instructions for Form 3520 (Rev. 12-2025)

Page 7 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
the U.S. owner. See section 6048(b)(2). In order to avoid 
this, a U.S. owner of a foreign trust should ensure that the 
foreign trust appoints a U.S. person to act as the foreign 
trust’s limited agent for purposes of applying sections 
7602, 7603, and 7604. The agency relationship must be 
established by the time Form 3520 is filed for the relevant 
tax year and must continue as long as the statute of 
limitations remains open for the relevant tax year.
In order to authorize a U.S. person to act as a U.S. 
agent under section 6048(b)(2) or for purposes of section 
6048(c)(2)(A), the foreign trust and the U.S. person must 
enter into a binding agreement substantially in the format 
of the AUTHORIZATION OF AGENT form in the 
Instructions for Form 3520-A, amended as required.
If the U.S. person’s responsibility as an agent of the 
foreign trust is terminated for any reason (for example, 
resignation, liquidation, or death), the U.S. owner of the 
foreign trust must make sure the foreign trust files an 
amended Form 3520-A with the IRS within 90 days. See 
section IV .B of Notice 97-34.
U.S. Beneficiary
A U.S. beneficiary generally includes any U.S. person that 
could possibly benefit, directly or indirectly, from the trust 
(including an amended trust) at any time, whether or not 
the person is designated in the trust instrument as a 
beneficiary and whether or not the person can receive a 
distribution from the trust in the current year. In addition, a 
U.S. beneficiary includes:
• A foreign corporation that is a controlled foreign 
corporation (as defined in section 957(a)),
• A foreign partnership if a U.S. person is a partner of the 
partnership, and
• A foreign estate or trust if the estate or trust has a U.S. 
beneficiary. See section II of Notice 97-34 and the 
regulations under section 679 for additional information.
Foreign trust treated as having a U.S. beneficiary. In 
general, if a U.S. person, directly or indirectly, transfers 
property to a foreign trust (other than a deferred 
compensation or charitable trust described in section 
6048(a)(3)(B)(ii)), the foreign trust will be treated as 
having a U.S. beneficiary unless the terms of the trust 
instrument specifically prohibit any distribution of income 
or corpus to a U.S. person at any time, even after the 
death of the U.S. transferor or any event terminating the 
trust, and the trust cannot be amended or revised to allow 
such a distribution. For these purposes, an amount will be 
treated as accumulated for the benefit of a U.S. person 
even if the U.S. person’s interest in the trust is contingent 
on a future event and regardless of whether anything is 
actually distributed to a U.S. person during that tax year.
Special rule in case of discretion to identify 
beneficiaries. For purposes of the general rule 
described earlier, if any person has the discretion of 
making a distribution from the trust to, or for the benefit of, 
any person, the trust will be treated as having a 
beneficiary who is a U.S. person unless the terms of the 
trust specifically identify the class of persons to whom 
such distributions may be made, and none of those 
persons are U.S. persons during the tax year.
Certain agreements and understandings treated as 
terms of the trust. For purposes of the general rule 
described earlier, if any U.S. person who directly or 
indirectly transfers property to the trust is directly or 
indirectly involved in any agreement or understanding 
(whether written, oral, or otherwise) that may result in the 
income or corpus of the trust being paid or accumulated 
to, or for the benefit of, a U.S. person, such agreement or 
understanding will be treated as a term of the trust.
Certain loans or uncompensated use of trust 
property. If a foreign trust is not already treated as having 
a U.S. beneficiary under the rules described earlier, the 
trust will be treated as having a U.S. beneficiary if, after 
March 18, 2010, either:
• The foreign trust loans cash or marketable securities, 
directly or indirectly, to a U.S. person, and the U.S. person 
does not repay the loan at a market rate of interest within a 
reasonable period of time; or
• A U.S. person, directly or indirectly, uses property that is 
owned by the foreign trust and does not pay FMV of the 
use of such property within a reasonable period of time.
Presumption that foreign trust has U.S. beneficiary. If 
a U.S. person, directly or indirectly, transfers property to a 
foreign trust (other than a deferred compensation or 
charitable trust described in section 6048(a)(3)(B)(ii)), the 
IRS may treat such trust as having a U.S. beneficiary for 
purposes of applying section 679(d) to such transfer if the 
IRS requests information with respect to the transfer and 
the U.S. person fails to demonstrate to the satisfaction of 
the IRS that no portion of the income or corpus of the trust 
may ever be paid to or accumulated for the benefit of a 
U.S. person.
U.S. Person
A U.S. person is:
• A citizen or resident of the United States, including dual 
residents who claim the benefits under an income tax 
treaty;
• A domestic partnership;
• A domestic corporation;
• Any estate (other than a foreign estate, within the 
meaning of section 7701(a)(31)(A)); and
• Any domestic trust (defined earlier).
For guidance on determining resident alien status, go 
to Pub. 519, U.S. T ax Guide for Aliens.
U.S. Transferor
A U.S. transferor is any U.S. person who:
1. Creates or settles a foreign trust;
2. Directly or indirectly transfers money or property to 
a foreign trust (this includes deemed transfers under 
section 679(a)(4) or section 679(a)(5));
3. Makes a sale to a foreign trust if the sale was at 
other than arm’s-length terms or was to a related foreign 
trust, or makes (or guarantees) a loan to a related foreign 
trust; or
4. Is the executor of the estate of a U.S. person and:
a. The decedent made a testamentary transfer (a 
transfer by reason of death) to a foreign trust;
b. Immediately prior to death, the decedent was 
treated as the owner of any portion of a foreign trust under 
the rules of sections 671 through 679; or
Instructions for Form 3520 (Rev. 12-2025) 7

Page 8 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
c. Any portion of a foreign trust’s assets were included 
in the estate of the decedent.
Generally, the person defined as the transferor is the 
responsible party (defined earlier) who must ensure that 
required information be provided or pay appropriate 
penalties.
Specific Instructions
Period Covered
For calendar-year filers, fill in the “calendar year” space at 
the top of the form. For fiscal-year filers, fill in the “tax year 
beginning” and “ending” spaces at the top of the form.
Item A—Initial Return, Final Return, 
Amended Return
Initial return. If this is the foreign trust’s first return, check 
the “Initial return” box.
Final return. If the foreign trust ceases to exist, check the 
“Final return” box.
Example. If you filed Form 3520 concerning 
transactions with a foreign trust and that trust terminated 
within the tax year, then the Form 3520 for the year in 
which the trust terminated would be a final return.
Amended return. If this Form 3520 is filed to amend a 
previously filed Form 3520, check the “Amended return” 
box.
Item C—Excepted Specified Foreign 
Financial Assets Reported
Check the box in item C only if the Form 3520 filer also 
files Form 8938 for the same tax year and includes this 
form in the total number of Forms 3520 reported on line 15 
of Part IV , Excepted Specified Foreign Financial Assets, of 
Form 8938. For more information, see the Instructions for 
Form 8938, generally, and in particular, Duplicative 
reporting and the specific instructions for Part IV .
Identifying Information
Taxpayer identification numbers (TINs). Use social 
security numbers (SSNs) or individual taxpayer 
identification numbers (ITINs) to identify individuals. Use 
employer identification numbers (EINs) to identify estates, 
trusts, partnerships, and corporations. Don’t use an SSN 
in place of an EIN.
Applying for an EIN. If the foreign trust does not have an 
EIN, the foreign trust or the U.S. owner may apply for one 
online at IRS.gov/EIN. If the foreign trust’s principal place 
of business is outside the United States or its territories, 
the foreign trust can apply for an EIN by phone at 
267-941-1099. See International EIN applicants under 
Other ways to apply for an EIN at IRS.gov/EIN.
Caution: Do not enter a PTIN in any entry space on Form 
3520 other than the entry space for “PTIN” at the bottom 
of page 6 of the form.
Address. Include the room, suite, or other unit number 
after the street address. If the post office does not deliver 
mail to the street address and the U.S. person has a P .O. 
box, show the box number instead.
Foreign address.  Do not abbreviate the country name.
Lines 1a and 1i. Line 1a identifies the person that is 
filing Form 3520. If you and your spouse are filing a joint 
Form 3520, put your names and TINs in the same order as 
they appear on your Form 1040, U.S. Individual Income 
T ax Return, or Form 1040-SR, U.S. T ax Return for Seniors, 
and check the box on line 1i.
Line 1j. If an automatic 2-month extension applies for 
your tax return, check the box and attach a statement to 
the Form 3520 showing that you are a U.S. citizen or 
resident who meets one of the following conditions.
• Y ou live outside of the United States and Puerto Rico 
and your place of business or post of duty is outside the 
United States and Puerto Rico.
• Y ou are in the military or naval service on duty outside 
the United States and Puerto Rico.
Line 1k.  If you filed for an extension of time to file your 
income tax return, check the box and enter the number of 
the tax return that you will be filing with the IRS.
Example. Y ou file Form 4868, Application for 
Automatic Extension of Time T o File U.S. Individual 
Income T ax Return, to extend the time to file your 
individual income tax return (Form 1040). Enter “1040” on 
the entry line.
Line 2b. Enter the EIN of the foreign trust. Do not enter 
an SSN or ITIN. Only an EIN should be used to identify 
the foreign trust.
Line 3. Check “No” if the foreign trust did not appoint a 
U.S. agent who can provide the IRS with all relevant trust 
information, and if you are required to complete Part I, 
complete lines 15 through 18.
Lines 4a through 4f. If you are filing Form 3520 for a 
U.S. decedent, you must provide information about the 
U.S. decedent on lines 4a through 4e. Y ou must also 
check the applicable box on line 4f.
Part I—Transfers by U.S. Persons to a 
Foreign Trust During the Current Tax 
Year
Complete Part I if you are responsible for reporting a 
reportable event that occurred during the current tax year, 
you transferred property to a related trust in exchange for 
a loan, or you hold a valid loan. See Who Must File, 
earlier.
For information on what is a reportable event, see 
Reportable Event, earlier.
Note: Although the basic reporting requirements for Part I 
of Form 3520 are contained in section 6048 (and are 
clarified by Notice 97-34), the reporting requirements have 
been further clarified by the regulations under sections 
679 and 684. Accordingly, the regulations under sections 
679 and 684 should be referred to for additional 
clarification for transfers that are required to be reported in 
Part I of Form 3520.
8 Instructions for Form 3520 (Rev. 12-2025)

Page 9 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Line 5a. Enter the name of the trust creator. If you are the 
trust creator, enter “Same as line 1a” on line 5a. If you are 
not the trust creator, enter the name of the person who 
created or originally settled the foreign trust.
Lines 5b and 5c.  Enter the address and TIN, if any, of 
the trust creator. See Identifying Information, earlier, for 
specific information regarding the entering of addresses 
and TINs.
If you are the trust creator, enter “Same as lines 1c, 1e, 
1f, 1g, and 1h” on line 5b, and enter “Same as line 1b” on 
line 5c.
Lines 6a and 6b. Enter the applicable two-letter country 
code from the list at IRS.gov/CountryCodes.
Lines 7 and 8. If you are reporting multiple transfers to a 
single foreign trust and the answers to line 7 or 8 are 
different for various transfers, complete a separate line for 
each transfer on duplicate copies of the relevant pages of 
the form.
Lines 7a and 7b. Check “Y es” if you are treated as a U.S. 
owner of any portion of the foreign trust under the grantor 
trust rules (sections 671 through 679). Y ou must also 
complete line 7b and Part II of this form. Additionally, if 
another person is treated as an owner of the transferred 
assets, you must comply with the reporting requirements 
that would apply to a direct transfer to that other person. 
For example, if that other person is a foreign partnership, 
you must comply with the reporting requirements for 
transfers to foreign partnerships. See Form 8865, Return 
of U.S. Persons With Respect to Certain Foreign 
Partnerships.
Line 8. If the transfer was a completed gift (see 
Regulations section 25.2511-2), you may have to file Form 
709, United States Gift (and Generation-Skipping 
T ransfer) T ax Return. If the transfer was a bequest, you 
may have to file Form 706, United States Estate (and 
Generation-Skipping T ransfer) T ax Return.
Line 9. See U.S. Beneficiary, earlier.
Schedule A—Obligations of a Related Trust
Complete the applicable portions of Schedule A with 
respect to all transfers to a related foreign trust in 
exchange for an obligation of the trust or a person related 
to the trust that took place during the current tax year.
Line 11. For additional information, see Obligation, 
Qualified Obligation, and Person related to a foreign trust, 
earlier.
Line 12. If you answered “Y es” to the question on line 11b 
with respect to any obligation, you must generally answer 
“Y es” to the question on line 12. By so doing, you agree to 
extend the period of assessment of any income or transfer 
tax attributable to the transfer and any consequential 
income tax changes for each year that the obligation is 
outstanding to a date 3 years after the maturity date of the 
obligation. When executed and filed, this form will be 
deemed to be agreed upon and executed by the IRS for 
purposes of Regulations section 301.6501(c)-1(d).
Y ou have the right to refuse to extend the period of 
assessment. Pub. 1035, Extending the T ax Assessment 
Period, provides a detailed explanation of your rights and 
the consequences of the choices you may make.
Note: If you answer “No” to the question on line 12, you 
generally may not treat an obligation as a qualified 
obligation on line 11b. The one exception to this is if the 
maturity date of the obligation does not extend beyond the 
end of your tax year for which you are reporting and such 
obligation is paid within that tax year.
Schedule B—Gratuitous Transfers
Complete the applicable portions of Schedule B with 
respect to all reportable events (defined earlier) that took 
place during the current tax year.
Line 13. 
• In your column (b) description, indicate whether the 
property is tangible or intangible.
• Y ou may aggregate transfers of cash during the year on 
a single line of line 13.
• If there is not enough space on the form, attach a 
statement.
• For transfers reported on statements attached to the 
form, you must enter “Statement” on one of the lines in 
column (b) and enter the total amount of transfers 
reported on the statement in columns (c), (d), (e), (f), (h), 
and (i) of line 13.
Note: Penalties may be imposed for failure to report all 
required information. See Penalties, earlier.
Line 13, column (d). Enter the U.S. adjusted basis of the 
property transferred.
Line 13, column (e). Only include gain that is 
immediately recognized at the time of the transfer.
Note: Any transfer of appreciated assets by a U.S. person 
to a foreign nongrantor trust is treated as a sale or 
exchange, and the transferor must recognize as gain the 
excess of the FMV of the transferred property over its 
adjusted basis. This rule applies to a domestic trust that 
becomes a foreign trust, provided that the foreign trust is 
not a grantor trust. The domestic trust is treated as having 
transferred all of its assets to the foreign trust immediately 
prior to becoming a foreign trust. Although the gain is not 
recognized on Form 3520, it must be reported on the 
appropriate form or schedule of the transferor’s income 
tax return. See section 684. The transfer of assets, 
however, is reported on Part I of this Form 3520.
Line 13, column (f). Generally, if the reported 
transaction is a sale, you should report the gain on the 
appropriate form or schedule of your income tax return.
Lines 15 through 18. If you checked “No” on line 3 and 
you are required to complete Part I, acknowledging that 
the foreign trust did not appoint a U.S. agent who can 
provide the IRS with all relevant trust information, 
complete lines 15 through 18.
Line 15. Enter the name, address, whether the person is 
a U.S. beneficiary (defined earlier), and TIN, if any, of all 
reportable beneficiaries. Include specified beneficiaries, 
classes of discretionary beneficiaries, and names or 
classes of any beneficiaries that could be named as 
Instructions for Form 3520 (Rev. 12-2025) 9

Page 10 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
additional beneficiaries. If there is not enough space on 
the form, attach a statement.
Line 17. Enter the name, address, and TIN, if any, of any 
person, other than those listed on line 16, that has 
significant powers over the trust (for example, “protectors,” 
“enforcers,” any person that must approve trustee 
decisions or otherwise direct trustees, any person with a 
power of appointment, or any person with powers to 
remove or appoint trustees, etc.). Include a description of 
each person’s powers. If there is not enough space, attach 
a statement.
Line 18. If you checked “No” on line 3, attach a copy of 
the following documents.
• A summary of the terms of the foreign trust that includes 
a summary of any oral agreements or understandings you 
have with the trustee, whether or not legally enforceable.
• A copy of all trust documents (and any revisions), 
including the trust instrument, any memoranda of wishes 
prepared by the trustee summarizing your wishes, any 
letter of wishes you’ve prepared summarizing your wishes, 
and any similar documents.
• A copy of the trust’s financial statements, including a 
balance sheet and an income statement similar to those 
shown on Form 3520-A. These financial statements must 
reasonably reflect the trust’s accumulated income under 
U.S. income tax principles. For example, the statements 
must not treat capital gains as additions to trust corpus.
• A copy of the trust’s organizational chart, including 
ownership structure and percentage of ownership.
Note: If these documents have been previously attached 
to a Form 3520-A or Form 3520 filed within the previous 3 
years, attach only relevant updates.
Schedule C—Qualified Obligations Outstanding 
in the Current Tax Year
Line 19. Provide information on the status of outstanding 
obligations of the related foreign trust (or an obligation of a 
person related to the foreign trust) that you reported as a 
qualified obligation in the current tax year. This information 
is required in order to retain the obligation’s status as a 
qualified obligation. If relevant, attach a statement 
describing any changes in the terms of the qualified 
obligation.
If the obligation fails to retain the status of a qualified 
obligation, you will be treated as having made a gratuitous 
transfer to the foreign trust, which must be reported on 
Schedule B of this Part I in the year the obligation fails to 
meet the criteria for a qualified obligation. See 
section III.C.2 of Notice 97-34.
Part II—U.S. Owner of a Foreign Trust
Complete Part II if you are considered the owner of any 
assets of a foreign trust under the rules of sections 671 
through 679 during the tax year. Y ou are required to enter 
an EIN for such foreign trust on line 2b on page 1 of the 
form.
Note: Y ou are required to complete Part II even if there 
have been no transactions involving the trust during the 
tax year. Y ou may also need to complete Part III if you 
receive a distribution from the foreign trust. See the 
instructions for Part III.
Line 20. Enter information regarding any person, 
including yourself, who is considered the owner of any 
portion of the trust under the rules of sections 671 through 
679. Also, enter in column (e) the specific Code section 
that causes you or any other person (as applicable) to be 
considered an owner for U.S. income tax purposes. See 
the grantor trust rules under sections 671 through 679.
Lines 21a and 21b. Enter the applicable two-letter code 
from the list at IRS.gov/CountryCodes.
Line 22. Check “Y es” if the foreign trust filed Form 3520-A 
for the current tax year and attach a copy of pages 3 and 4 
(Foreign Grantor T rust Owner Statement) of the Form 
3520-A. See section IV of Notice 97-34.
Check “No” if the foreign trust has not filed Form 
3520-A for the current tax year and attach a substitute 
Form 3520-A that you have completed to the best of your 
ability.
Caution: Y ou may be liable for a penalty equal to the 
greater of $10,000 or 5% of the gross value of the portion 
of trust assets that you are treated as owning. There are 
additional penalties for continuing failure to file after notice 
by the IRS. See section 6677(a) through (c). Also, see 
Penalties, earlier.
Line 23. Enter the FMV of the trust assets that you are 
treated as owning. Include all assets at FMV as of the end 
of the tax year. For this purpose, disregard all liabilities. 
The trust should send you this information in connection 
with its Form 3520-A. If you did not receive such 
information (line 9 of the Foreign Grantor T rust Owner 
Statement) from the trust, complete line 23 to the best of 
your ability. At a minimum, include the value of all assets 
that you have transferred to the trust.
Use Form 8082 to notify the IRS that you did not 
receive a Foreign Grantor T rust Owner Statement. 
However, filing Form 8082 does not relieve you of any 
penalties that may be imposed under section 6677. See 
Penalties, earlier.
Part III—Distributions to a U.S. Person 
From a Foreign Trust During the 
Current Tax Year
Complete Part III if you are a U.S. person who received a 
distribution from a foreign trust during the current tax year.
If you received an amount from a portion of a foreign 
trust of which you are treated as the owner, complete lines 
24 and 27. If you received an amount from a foreign trust 
that would require a report under both Parts III and IV (gifts 
or bequests) of Form 3520, report the amount only in Part 
III.
Line 24. Report any cash or the FMV of other property 
that you received (actually or constructively, directly or 
indirectly) from a foreign trust during the current tax year, 
whether or not taxable, unless the amount is a loan to you 
from the trust or constitutes uncompensated use of trust 
property, both of which must be reported on line 25. For 
example, if you are a partner in a partnership that receives 
a distribution from a foreign trust, you must report your 
10 Instructions for Form 3520 (Rev. 12-2025)

Page 11 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
allocable share of such payment as an indirect distribution 
from the trust.
Line 24, column (c). The filer is permitted to enter the 
basis of the property in the hands of the beneficiary (as 
determined under section 643(e)(1)), if lower than the 
FMV of the property, but only if the taxpayer is not required 
to complete Schedule A (lines 31 through 38) due to lack 
of documentation. For these purposes, lack of 
documentation refers to a situation in which the filer 
checked “No” on line 29 or 30 because (a) the beneficiary 
did not receive a Foreign Grantor T rust Beneficiary 
Statement or a Foreign Nongrantor T rust Beneficiary 
Statement from the trust, or (b) such statement did not 
contain all of the items specified under the instructions for 
line 29 or 30, later.
If you received a distribution from a foreign trust 
attributable to a gift or bequest from a covered expatriate, 
you may have to file Form 708, United States Return of 
T ax for Gifts and Bequests Received From Covered 
Expatriates. See sections 877A and 2801, and What’s 
new—Estate and gift tax, available at IRS.gov/
Businesses/Small-Businesses-Self-Employed/Whats-
New-Estate-and-Gift- T ax.
Line 25. If you or a U.S. person related to you received a 
loan of cash or marketable securities, directly or indirectly, 
from a related foreign trust, or the uncompensated use of 
trust property (defined later), the amount of such loan or 
the FMV of the use of trust property will be treated as a 
reportable distribution, whether or not taxable. For this 
purpose, a loan to you by an unrelated third party that is 
guaranteed by a foreign trust is generally treated as a loan 
from the trust.
Line 25, column (e). Answer “Y es” if an obligation 
given in exchange for the loan is a qualified obligation 
(defined earlier).
Line 25, column (f).  The FMV of an obligation is zero 
unless it is a qualified obligation. Therefore, in the case of 
obligations that are not qualified obligations, enter “-0-” in 
column (f).
Uncompensated use of trust property. If you or a 
U.S. person related to you, directly or indirectly, used any 
property of a foreign trust, the FMV of such use will be 
treated as a reportable distribution whether or not taxable. 
Report the FMV of the use of trust property in column (a) 
and the date of first use in column (b), skip columns (c) 
through (e), report the amount paid for such use in column 
(f), and enter the amount treated as a taxable distribution 
from the trust in column (g) by subtracting column (f) from 
column (a). See section 643(i) for more information.
Note: Under the HIRE Act, effective after March 18, 2010, 
if a foreign trust with a U.S. transferor is not already 
treated as a grantor trust under the rules of sections 671 
through 679, the foreign trust will be treated as having 
acquired a U.S. beneficiary and will therefore be treated 
as a grantor trust, if it makes a loan of cash or marketable 
securities, directly or indirectly, to a U.S. person or allows 
a U.S. person, directly or indirectly, to use trust property, 
and the U.S. person does not repay the loan at a market 
rate of interest or pay the trust the FMV of the use of the 
property within a reasonable period of time. Accordingly, 
the loan or use of trust property will not be treated as a 
taxable distribution under section 643(i) but will remain 
reportable on Part III of this Form 3520.
Line 26. If you checked “Y es” in column (e) of line 25, you 
must generally check “Y es” on line 26. By doing so, you 
agree to extend the period of assessment of any income 
or transfer tax attributable to the transfer and any 
consequential income tax changes for each year that the 
obligation is outstanding to a date 3 years after the 
maturity date of the obligation. When executed and filed, 
this form will be deemed to be agreed upon and executed 
by the IRS for purposes of Regulations section 
301.6501(c)-1(d).
Y ou have a right to refuse to extend the period of 
assessment. See Pub. 1035 for a detailed explanation of 
your rights.
Line 27. Penalties may be imposed for failure to 
accurately report all distributions received during the 
current tax year. See Penalties, earlier.
Line 28. Provide information on the status of any 
outstanding obligation to the foreign trust that you 
reported as a qualified obligation in the current tax year. 
This information is required in order to retain the 
obligation’s status as a qualified obligation. If relevant, 
attach a statement describing any changes to the terms of 
the qualified obligation. If the obligation fails to retain the 
status of a qualified obligation, you will be treated as 
having received a taxable distribution under section 643(i) 
from the foreign trust. See section V .A of Notice 97-34.
Line 29. Check “Y es” if you received a Foreign Grantor 
T rust Beneficiary Statement (page 5 of Form 3520-A) from 
the foreign trust with respect to a distribution. Attach the 
Foreign Grantor T rust Beneficiary Statement from the 
foreign trust and do not complete the rest of Part III with 
respect to the distribution.
If a U.S. beneficiary receives a complete Foreign 
Grantor T rust Beneficiary Statement with respect to a 
distribution during the tax year, the beneficiary should 
treat the distribution for income tax purposes as if it came 
directly from the owner. For example, if the distribution is a 
gift, the beneficiary should not include the distribution in 
gross income.
In addition to basic identifying information (see 
Identifying Information, earlier) about the foreign trust and 
its trustee, this statement must contain these items.
1. The first and last day of the tax year of the foreign 
trust to which this statement applies.
2. An explanation of the facts necessary to establish 
that the foreign trust should be treated for U.S. tax 
purposes as owned by another person. The explanation 
should identify the Code section that treats the trust as 
owned by another person.
3. A statement identifying whether the owner of the 
trust is an individual, trust, corporation, or partnership.
4. A description of property (including cash) 
distributed or deemed distributed to the U.S. person 
during the tax year and the FMV of the property 
distributed.
5. A statement that the trust will permit either the IRS 
or the U.S. beneficiary to inspect and copy the trust’s 
Instructions for Form 3520 (Rev. 12-2025) 11

Page 12 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
permanent books of account, records, and such other 
documents that are necessary to establish that the trust 
should be treated for U.S. tax purposes as owned by 
another person. This statement is not necessary if the 
trust has appointed a U.S. agent.
6. A statement as to whether the foreign trust has 
appointed a U.S. agent (defined earlier). If the trust has a 
U.S. agent, include the name, address, and TIN of the 
agent.
If any of the items required for the Foreign Grantor T rust 
Beneficiary Statement is missing, you must check “No.”
Also, if you answer “Y es” and the foreign trust or U.S. 
agent does not produce records or testimony when 
requested or summoned by the IRS, the IRS may 
redetermine the tax consequences of your transactions 
with the trust and impose appropriate penalties under 
section 6677. See section 6048(c)(2)(A).
Caution: If a foreign nongrantor trust or the question is 
not applicable, check “N/A.”
Line 30. Check “Y es” if you received a Foreign 
Nongrantor T rust Beneficiary Statement from the foreign 
trust with respect to a distribution. Attach the Foreign 
Nongrantor T rust Beneficiary Statement from the foreign 
trust. A Foreign Nongrantor T rust Beneficiary Statement 
must include the following items.
1. An explanation of the appropriate U.S. tax treatment 
of any distribution or deemed distribution for U.S. tax 
purposes or sufficient information to enable the U.S. 
beneficiary to establish the appropriate treatment of any 
distribution or deemed distribution for U.S. tax purposes.
2. A statement identifying whether any grantor of the 
trust is a partnership or a foreign corporation. If so, attach 
an explanation of the relevant facts.
3. A statement that the trust will permit either the IRS 
or the U.S. beneficiary to inspect and copy the trust’s 
permanent books of account, records, and such other 
documents that are necessary to establish the appropriate 
treatment of any distribution or deemed distribution for 
U.S. tax purposes. This statement is not necessary if the 
trust has appointed a U.S. agent.
4. The Foreign Nongrantor T rust Beneficiary 
Statement must also include items (1), (4), and (6), as 
listed in the line 29 instructions, earlier, in addition to the 
basic identifying information (see Identifying Information, 
earlier) about the foreign trust and its trustee.
If any of items required for the Foreign Nongrantor T rust 
Beneficiary Statement is missing, you must check “No.”
Also, if you answer “Y es” and the foreign trust or U.S. 
agent does not produce records or testimony when 
requested or summoned by the IRS, the IRS may 
redetermine the tax consequences of your transactions 
with the trust and impose appropriate penalties under 
section 6677. See section 6048(c)(2)(A).
Caution: If a foreign grantor trust, or the question is not 
applicable, check “N/A.”
Schedule A—Default Calculation of Trust 
Distributions
If you answered “Y es” to line 30, you may complete either 
Schedule A or Schedule B. Generally, if you complete 
Schedule A in the current year, or did so in prior years, you 
must continue to complete Schedule A for all future years, 
even if you are able to answer “Y es” to line 30 in that future 
year. The only exception to this consistency rule is that 
you may use Schedule B in the year that a trust 
terminates, but only if you are able to answer “Y es” to 
line 30 in the year of termination.
Line 32. T o the best of your knowledge, state the number 
of years the trust has been in existence as a foreign trust 
and attach an explanation of your basis for this statement. 
Consider any portion of a year to be a complete year. If 
this is the first year that the trust has been a foreign trust, 
do not complete the rest of Part III.
Line 33. Enter the total amount of distributions that you 
received during the 3 preceding tax years or the number 
of years the trust has been a foreign trust if fewer than 3 
years. For example, if a trust distributed $50 in year 1, 
$120 in year 2, and $150 in year 3, the amount reported 
on line 33 would be $320 ($50 + $120 + $150).
Line 35. Divide line 34 by 3.0 or the number of years the 
trust has been a foreign trust if fewer than 3 years. 
Consider any portion of a year to be a complete year. For 
example, a foreign trust created on July 1, 2021, would be 
treated on a 2023 calendar year return as having 2 
preceding years (2021 and 2022). In this case, you would 
calculate the amount on line 35 by dividing line 34 by 2.0. 
Do not disregard tax years in which no distributions were 
made. The IRS will consider your proof of these prior 
distributions as adequate records to demonstrate that any 
distribution up to the amount on line 31 is not an 
accumulation distribution in the current tax year.
Line 36. Enter this amount as ordinary income on your 
income tax return. Report this amount on the appropriate 
schedule of your income tax return (for example, 
Schedule E (Form 1040), Part III).
Line 37. If there is an amount on line 37, you must also 
complete line 38 and Schedule C—Calculation of Interest 
Charge to determine the amount of any interest charge 
you may owe.
Schedule B—Actual Calculation of Trust 
Distributions
Y ou may only use Schedule B if:
• Y ou answered “Y es” to line 30,
• Y ou attach a copy of the Foreign Nongrantor T rust 
Beneficiary Statement to this return, and
• Y ou have never before used Schedule A for this foreign 
trust or this foreign trust terminated during the tax year.
Line 40a. Enter on line 40a the amount received by you 
from the foreign trust that is treated as ordinary income of 
the trust in the current tax year. Ordinary income is all 
income that is not capital gains. Report this amount on the 
appropriate schedule of your tax return (for example, 
Schedule E (Form 1040), Part III).
Lines 42a through 42d. Enter on these lines the 
applicable amounts received by you from the foreign trust 
12 Instructions for Form 3520 (Rev. 12-2025)

Page 13 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
that are treated as capital gain income of the trust in the 
current tax year. Report these amounts on the appropriate 
schedule of your tax return (for example, Schedule D 
(Form 1040)).
Line 45. Enter the foreign trust’s aggregate undistributed 
net income (UNI).
Example. A trust was created in 2018 and has made 
no distributions prior to 2024. Assume the trust’s ordinary 
income was $0 in 2023, $60 in 2022, $124 in 2021, $87 in 
2020, $54 in 2019, and $25 in 2018. Thus, for 2024, the 
trust’s UNI would be $350. If the trust earned $100 and 
distributed $200 during 2024 (so that $100 was distributed 
from accumulated earnings), the trust’s 2025 aggregate 
UNI would be $250 ($350 + $100 − $200).
Line 46. Enter the foreign trust’s weighted undistributed 
net income (weighted UNI). The trust’s weighted UNI is its 
accumulated income that has not been distributed, 
weighted by the years that it has accumulated income. T o 
calculate weighted UNI, multiply the undistributed income 
from each of the trust’s years by the number of years since 
that year, and then add each year’s result. Using the 
example from line 45, the trust’s weighted UNI in 2024 
would be $1,260, calculated as follows.
Year
No. of 
years 
since that 
year
UNI from 
each year Weighted UNI
2023 1 $ 0 $ 0
2022 2  60 120
2021 3 124 372
2020 4  87 348
2019 5  54 270
2018 6  25 150
TOTAL $350 $1,260
T o calculate the trust’s weighted UNI for 2025, the trust 
could update this calculation, or the weighted UNI shown 
on line 46 of the 2024 Form 3520 could simply be updated 
using the following steps.
1. Begin with the 2024 weighted UNI.
2. Add UNI at the beginning of 2024.
3. Add trust earnings in 2024.
4. Subtract trust distributions in 2024.
5. Subtract weighted trust accumulation distributions 
in 2024. The weighted trust accumulation distributions are 
the trust accumulation distributions in 2024 multiplied by 
the applicable number of years from 2024.
Using the example above, the trust’s 2025 weighted 
UNI would be $1,150, calculated as follows.
2024 weighted UNI ..................... $1,260
UNI at beginning of 2024 ................. + 350
T rust earnings in 2024 ................... + 100
T rust distributions in 2024 ................ − 200
Weighted trust accumulation distributions in 2024
 ($100 X 3.6) ....................... – 360
2025 weighted UNI ..................... $1,150
Line 47. Calculate the trust’s applicable number of years 
by dividing line 46 by line 45. This would be the weighted 
UNI divided by the annual UNI. Using the examples in the 
instructions for lines 45 and 46, the trust’s applicable 
number of years would be 3.6 (1,260/350) in 2024 and 4.6 
(1,150/250) in 2025.
Note: Include as many decimal places as there are digits 
in the UNI on line 45. For example, using the example in 
the instructions for line 45, include three decimal places.
Schedule C—Calculation of Interest Charge
Complete Schedule C if you entered an amount on line 37 
or line 41a.
Line 49. Include the amount from line 48 of this form on 
line 1 of Form 4970, T ax on Accumulation Distribution of 
T rusts. Then, compute the tax on the total accumulation 
distribution using lines 1 through 28 of Form 4970. Enter 
on line 49 the tax from line 28 of Form 4970.
Note: Use Form 4970 as a worksheet and attach it to 
Form 3520.
Line 51. Interest accumulates on the tax (line 49) for the 
period beginning on the date that is the applicable number 
of years (as rounded on line 50) prior to the applicable 
date and ending on the applicable date. For purposes of 
making this interest calculation, the applicable date is the 
date that is mid-year through the tax year for which 
reporting is made. For example, in the case of a 2025 
calendar-year taxpayer, the applicable date would be 
June 30, 2025.
Alternatively, if you received only a single distribution 
during the tax year that is treated as an accumulation 
distribution, you may use the date of that distribution as 
the applicable date.
For portions of the interest accumulation period that are 
prior to 1996 and after 1976, interest accumulates at a 
simple rate of 6% annually, without compounding. For 
portions of the interest accumulation period that are after 
1995, interest is compounded daily at the rate imposed on 
underpayments of tax under section 6621(a)(2). This 
compounded interest for periods after 1995 is imposed 
not only on the tax, but also on the total simple interest 
attributable to pre-1996 periods.
If you are a calendar-year taxpayer and you use June 
30 of the calendar year as the applicable date for 
calculating interest, use the table found on IRS.gov/
CombinedInterestRate to determine the combined interest 
rate and enter it on line 51. If you are not a calendar-year 
taxpayer or you choose to use the actual date of the 
distribution as the applicable date, calculate the combined 
Instructions for Form 3520 (Rev. 12-2025) 13

Page 14 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
interest rate using the above principles and enter it on 
line 51.
Line 53. Report this amount as additional tax (ADT) on 
the appropriate line of your income tax return. For 
example, Form 1040 filers include this amount as part of 
the total for the “Any other taxes” line on Schedule 2 (Form 
1040) under Part II—Other T axes.
Part IV—U.S. Recipients of Gifts or 
Bequests Received During the 
Current Tax Year From Foreign 
Persons
Complete Part IV if you are a U.S. person who has 
received gifts or bequests from a foreign person or estate.
A gift to a U.S. person does not include any amount 
paid for qualified tuition or medical payments made on 
behalf of the U.S. person.
If a foreign trust makes a distribution to a U.S. person, 
the U.S. person must report the amount as a distribution in 
Part III, rather than as a gift in Part IV .
Note: If you fail to timely report foreign gifts that should be 
reported under section 6039F , the IRS may determine the 
income tax consequences of the receipt of such gift, and 
penalties may be imposed. See Penalties, earlier.
Contributions of property by foreign persons to 
domestic or foreign trusts that have U.S. beneficiaries are 
not reportable by those beneficiaries in Part IV unless they 
are treated as receiving the contribution in the year of the 
transfer. For example, if the U.S. beneficiary is treated as 
an owner of that portion of the trust under section 678, 
then the contribution must be reported by such U.S. 
beneficiary in Part IV .
A domestic trust that is not treated as owned by 
another person is required to report the receipt of a 
contribution to the trust from a foreign person as a gift in 
Part IV .
A domestic trust that is treated as owned by a foreign 
person is not required to report the receipt of a 
contribution to the trust from a foreign person. However, a 
U.S. person should report the receipt of a distribution from 
a domestic trust that is treated as owned by a foreign 
person as a gift from a foreign person in Part IV , rather 
than as a distribution to a U.S. person in Part III.
Line 54. Check “Y es” if during the current tax year, you 
received more than $100,000 that you treated as gifts or 
bequests from a nonresident alien, including a distribution 
received from a domestic trust treated as owned by a 
foreign person or a foreign estate. Complete columns (a) 
through (c).
T o calculate the threshold amount of $100,000, you 
must aggregate gifts from different foreign nonresident 
aliens and foreign estates if you know, or have reason to 
know, that those persons are related to each other or if 
one is acting as a nominee or intermediary for the other. 
See Related Person, earlier.
For example, if you receive a gift of $75,000 from Abby, 
a nonresident alien individual, and a gift of $40,000 from 
Brian, a nonresident alien individual, and you know that 
Abby and Brian are related, you must answer “Y es” and 
complete columns (a) through (c) for each gift.
However, if you answered “Y es” but none of the 
individual gifts or bequests received exceeds $5,000, do 
not complete columns (a) through (c). Instead, enter in 
column (b) of the first line, “No gifts or bequests exceed 
$5,000.”
If you received a gift or bequest from a covered 
expatriate, you may have to file Form 708. See sections 
877A and 2801, and What’s New—Estate and gift tax for 
additional information.
Line 55. Check “Y es” if you received aggregate amounts 
in excess of the section 6039F threshold amount during 
the current tax year that you treated as gifts from any of 
the following.
• Foreign corporations.
• Foreign partnerships.
• Any foreign persons that you know or have reason to 
know that are related to such foreign corporations or 
foreign partnerships.
For example, if you, a calendar-year taxpayer during 
2023, received $8,000 from Xander Corp. (a foreign 
corporation) that you treated as a gift, and $15,000 that 
you received from Allison (a nonresident alien) that you 
treated as a gift, and you know that Xander Corp. is wholly 
owned by Allison, you must complete columns (a) through 
(g) for each gift.
T o obtain the threshold amount, go to IRS.gov/
InflationAdjustment. Select the applicable tax year news 
release, then click on the Rev. Proc. link and search for 
section 6039F to see the threshold amount under Notice 
of Large Gifts Received from Foreign Persons.
Note: Gifts from foreign corporations or foreign 
partnerships are subject to recharacterization by the IRS 
under section 672(f)(4).
Line 56. Check “Y es” if you have any reason to believe 
that the foreign donor, in making any gift or bequest 
described in lines 54 and 55, was acting as a nominee or 
intermediary for any other person. If the ultimate donor on 
whose behalf the reporting donor is acting is a foreign 
corporation or foreign partnership, attach an explanation 
including the ultimate foreign donor’s name, address, TIN 
(if any) and whether it is a corporation or partnership.
If the ultimate donor is a foreign trust, treat the amount 
received as a distribution from a foreign trust and 
complete Part III.
Privacy Act and Paperwork Reduction Act Notice. We 
ask for the information on this form to carry out the Internal 
Revenue laws of the United States. Y ou are required to 
give us the information. We need it to ensure that you are 
complying with these laws and to allow us to figure and 
collect the right amount of tax.
Our authority to ask for information is sections 6001, 
6011, and 6012(a) and their regulations, which require you 
to file a return or statement with us for any tax for which 
you are liable. Y our response is mandatory under these 
sections. Section 6109 requires you to provide your TIN. 
Y ou must fill in all parts of the tax form that apply to you.
14 Instructions for Form 3520 (Rev. 12-2025)

Page 15 of 15  Fileid: … orm-3520/202512/a/xml/cycle06/source 15:44 - 7-Oct-2025
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Y ou are not required to provide the information 
requested on a form that is subject to the Paperwork 
Reduction Act unless the form displays a valid OMB 
control number. Books or records relating to a form or its 
instructions must be retained as long as their contents 
may become material in the administration of any Internal 
Revenue law. Generally, tax returns and return information 
are confidential, as required by section 6103. However, 
section 6103 allows or requires the IRS to disclose or give 
the information shown on your tax return to others as 
described in the Code. For example, we may disclose your 
tax information to the Department of Justice to enforce the 
tax laws, both civil and criminal, and to cities, states, the 
District of Columbia, and U.S. commonwealths or 
territories to carry out their tax laws. We may also disclose 
this information to other countries under a tax treaty, to 
federal and state agencies to enforce federal nontax 
criminal laws, or to federal law enforcement and 
intelligence agencies to combat terrorism. Failure to 
provide this information, or providing false information, 
may subject you to fines or penalties.
Keep this notice with your records. It may help you if we 
ask you for other information.
The time needed to complete and file this form and 
related schedules will vary depending on individual 
circumstances. The estimated burden for individual 
taxpayers filing this form is approved under OMB control 
number 1545-0074 and is included in the estimates 
shown in the instructions for their individual income tax 
return. The estimated burden for all other taxpayers who 
file this form is shown below.
Recordkeeping ...................... 42 hr., 34 min.
Learning about the law or the form......... 4 hr., 50 min.
Preparing the form ...................  6 hr., 40 min.
Sending the form to the IRS .............  16 min.
If you have comments concerning the accuracy of 
these time estimates or suggestions for making this form 
simpler, we would be happy to hear from you. Y ou can 
send us comments through IRS.gov/FormComments. Or, 
you can write to the Internal Revenue Service, T ax Forms 
and Publications, 1111 Constitution Ave. NW, IR-6526, 
Washington, DC 20224. Do not send the form to this 
office. Instead, see When and Where T o File, earlier.
Instructions for Form 3520 (Rev. 12-2025) 15