Foreign Trust Information Reporting | August 21 2024 Hearing Recap | Form 3520-A Form 3520

For help with a International US tax issue go to https://www.irsmedic.com/offshore

Is your tax-advantaged foreign retirement plan just a retirement plan or is it a "foreign trust" for US tax purposes requiring the filing of a Form 3520-A. and/or Form 3520?

The answer is quite difficult to pin down. . The IRS has proposed new regulations.

Links:

[REG-124850-08]
https://www.federalregister.gov/docum...
SEAT Submission:
https://seatnow.org/2024/06/26/seat-s...
Public Comments:
https://www.regulations.gov/search?fi...

The US Treasury Dept has conducted a hearing on August 21, 2024 reflecting the comments made. Long time guest John Richardson attended the hearing and is reporting back his findings for the IRSMedic community.

Is the IRS going to offer clarity? Will if offer it reasons why it deems things that are not foreign trusts to be foreign trust? Will the IRS new regulations comport with Loper-Bright or will the IRS be still able to get away by creating regulations few would ever ask for.

Join host Anthony E. Parent, Esq. as he discusses the problems and outlook for those with tax-advantaged foreign retirement accounts with John Richardson of Citizenshipsolutions.ca and Keith Redmond, Advocate for and Consulate to the American overseas as they examine the current state of regulations and hopefully offer some insights on the to pros and cons of Form 3520-A and Form 3520 filing.