Form 3520-A (2015) Tax Year Checklist
Purpose and 2015 Context
Form 3520-A reports annual income, distributions, and assets of foreign trusts with U.S. owners under IRC §6048(b). The IRS clarified for 2015 that trustees must report the Reference ID number on all owner and beneficiary statements. All amounts must be reported in U.S. dollars with English documentation only.
Filing Requirements
Determine Filing Obligations
A foreign trust with any U.S. owner or U.S. beneficiary receiving distributions must file Form 3520-A for the 2015 tax year. You must verify whether the trust qualifies as a foreign grantor trust or foreign non-grantor trust under IRC §679, as this classification determines which statements you must prepare and attach.
Complete Part I General Information
Enter the foreign trust's name, EIN (if assigned), and the Reference ID number as referenced in the instructions. Check boxes for initial, final, or amended return status. Mark whether any excepted specified foreign financial assets are reported, as the 2015 guidance required U.S. owners to disclose FATCA-reportable assets.
Determine U.S. Agent Appointment Status
If no U.S. agent was appointed under IRC §6048(b)(2), you must attach copies of the complete trust instrument, all written and oral agreements, memoranda of wishes, subsequent variances, and other trust documents. If documents were attached to a 3520-A filed in 2012, 2013, or 2014, only attach updates and document the year previously filed.
Report Trust Property Transfers
Mark "Yes" on Part I, line 5 if the trust transferred property (including cash) to any person during calendar year 2015, and attach a detailed statement. The 2015 instructions define "person" to include individuals, estates, trusts, partnerships, and corporations.
Complete Part II Foreign Trust Income Statement
Report all 2015 income items, including interest, dividends, rents, royalties, capital gains and losses, partnership income, ordinary gains and losses, and other income. Attach a statement identifying the source and nature of the "Other income" line. You must report gross amounts before expense reduction and avoid netting income and expenses on individual lines.
Report All 2015 Expenses
- Include foreign taxes and attach a statement showing a country-by-country breakdown.
- Report state and local taxes, interest expense, and depreciation or amortization.
- List trustee and advisor fees paid during the tax year.
- Report charitable contributions allowed under IRC §642(c) for trusts, and attach a statement if any charitable gifts were made.
- Include other expenses with attached statements, identifying the type and amount.
Complete Part III Foreign Trust Balance Sheet
Report cash, receivables, securities, real property, and depreciable assets (net of accumulated depreciation) at fair market value as of January 1, 2015 (column a) and December 31, 2015 (columns b through d showing cost, depreciation, and FMV). List all liabilities and reconcile to the net worth sections.
Prepare Foreign Grantor Trust Owner Statements
For each person treated as the owner of any portion of the trust under IRC §671 through 679, prepare an individual statement on page 3. Line 7 must contain a legal analysis citing the specific IRC section establishing grantor trust status.
Line 9 shows the owner's pro-rata share of trust corpus at fair market value. The trustee must sign the statement, attach it to Form 3520-A, and send a copy to the owner.
Prepare Foreign Grantor Trust Beneficiary Statements
For each U.S. person receiving a distribution or deemed distribution during 2015, complete a separate statement on page 4. Describe the property distributed, its fair market value, and any property used without compensation.
Line 8 requires legal analysis under IRC sections establishing non-grantor ownership. Indicate whether the trust owner is an individual, a partnership, or a corporation.
Complete Statement of Foreign Trust Income
Allocate each income and expense item from Part II proportionately to each owner on page 3. Distinguish taxable interest from tax-exempt interest and ordinary dividends from qualified dividends. Each owner receives items on proper schedules of their 2015 tax return (Form 1040, Schedule B, D, etc.), and you must attach foreign tax statements for credits.
Assemble Form With Required Materials
Bind Form 3520-A (pages 1 through 2), all completed owner statements, all beneficiary statements, all expense and income attachment statements, trust document copies (or reference to prior filing), and any statements regarding property transfers. Each statement must be signed and dated by the trustee under penalties of perjury.
Execute Trustee Signature and Submit
The trustee (or authorized officer) must sign Form 3520-A under penalties of perjury, providing title and signature date. Form 3520-A for the 2015 calendar year must be filed by the 15th day of the 3rd month after the end of the trust's tax year. Include paid preparer block if applicable.
2015 Year-Specific Regulatory Updates
- The 2015 instructions required all foreign trusts to provide a Reference ID number (line 1b(2)) on Form 3520-A and all owner and beneficiary statements for foreign trust identification.
- The 2015 form explicitly stated "All information must be in English" and "Show all amounts in U.S. dollars." Non-English trust documents required certified English translations to reinforce FATCA-era compliance requirements.
- Line 2 of Part I included a checkbox asking whether any excepted specified foreign financial assets under IRC §1471 through 1474 are reported. This reflected 2015 FATCA compliance obligations and required disclosure of account numbers and jurisdictions.
- Line 2e(ii) permitted reference to trust documents previously attached to Forms 3520-A filed in 2012, 2013, or 2014, reducing duplicate submission requirements for unchanged trust instruments.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
