Form 3520-A (2017) Checklist
Overview and Scope
Foreign trusts with at least one U.S. owner must file Form 3520-A to satisfy annual information reporting requirements under IRC §6048(b) for the 2017 tax year. You must prepare separate owner statements and beneficiary statements for each qualifying U.S. person, determine whether the trust appointed a U.S. agent, and attach comprehensive trust documentation unless identical copies were filed within the previous three years.
Filing Requirements and Deadlines
When to File
The filing deadline falls on the 15th day of the 3rd month after the end of the trust's tax year for calendar year 2017 or fiscal years beginning in 2017. You must send copies of the Foreign Grantor Trust Owner Statement and Foreign Grantor Trust Beneficiary Statement to the respective U.S. persons by the same deadline, and you may request an extension by submitting Form 7004.
Where to File
File the complete Form 3520-A with the Internal Revenue Service Center, P.O. Box 409101, Ogden, UT 84409. Canadian registered retirement savings plans (RRSPs), registered retirement income funds (RRIFs), and certain other Canadian retirement plans are exempt from filing Form 3520-A for U.S. citizen or resident alien owners or beneficiaries.
Initial Filing Steps
1. Mark Return Status
- Check the appropriate box on page 1 for initial return, final return, or amended return.
- Mark the "Excepted Specified Foreign Financial Assets" box only if a U.S. owner files Form 8938 and includes this form in the total number of Forms 3520-A reported on line 2 of Part IV of Form 8938.
2. Complete Trust Identification Information
- Enter the foreign trust's legal name, employer identification number (if assigned), and reference ID number on line 1b(2) if no EIN was entered on line 1b(1).
- Provide the complete address, including street, city, state or province, ZIP or postal code, and country.
- The reference ID number must be alphanumeric, contain no special characters or spaces, and remain consistent from year to year.
3. Answer U.S. Agent Question and Provide Documents
- If the trust appointed a U.S. agent in 2017, answer "Yes" on line 2 and complete lines 3a through 3g.
- If "No," attach copies of all trust documents: summary of written and oral agreements, trust instrument, memoranda or letters of wishes, subsequent variances, and other trust documents.
- Mark "Previous Year Attached" only if identical documents were submitted with a 3520-A filed within the prior 3 years; otherwise, attach all updates.
4. Authorize U.S. Agent (If Applicable)
- The trust and agent must enter into a binding agreement that allows the U.S. person to act as the trust's authorized agent for IRS purposes under sections 7602, 7603, and 7604.
- A U.S. grantor, U.S. beneficiary, or domestic corporation controlled by the grantor or beneficiary may act as a U.S. agent.
- Attach a copy of the authorization agreement to Form 3520-A using the format provided in the instructions.
Part I: General Information
Trustee and Agent Details
Complete lines 3a through 3g for the U.S. agent or lines 4a through 4g for the trustee. The agent or trustee information must include the identification number, full address, and country. If no agent is appointed, the trustee's address becomes the primary contact information for IRS correspondence regarding the 2017 tax year.
Property Transfers
On line 5, answer whether the trust transferred property (including cash) to another person during the 2017 tax year. Property transfer includes all distributions, gifts, loan forgiveness, and indirect benefits. If "Yes," attach a detailed statement providing the recipient's name, U.S. taxpayer identification number, country of organization, description of the transfer, and consideration received.
Part II: Foreign Trust Income Statement
Income Reporting
Report all income from U.S. and non-U.S. sources on lines 1 through 7. Enter interest, dividends, rents and royalties, partnership and fiduciary income, net short-term and long-term capital gains, ordinary gains, and other income. The financial statement must reasonably reflect the trust's income under U.S. income tax principles. Total income appears on line 8.
Expense Deductions
Enter expenses on lines 9 through 14. Report interest expense, foreign taxes, state and local taxes, amortization and depreciation, trustee and advisor fees, charitable contributions, and other expenses. Do not deduct federal income taxes, estate or gift taxes, or federal duties and excise taxes. Calculate net income or loss on line 16 by subtracting total expenses from total income.
Distribution Information
Line 17a shows the fair market value of total distributions to all persons during 2017. Lines 17b and 17c require separate identification of U.S. owners and U.S. beneficiaries receiving distributions with name, identification number, distribution date, and fair market value. Each recipient must receive a corresponding Foreign Grantor Trust Owner Statement or Beneficiary Statement.
Part III: Foreign Trust Balance Sheet
Report asset values in columns a and b for the beginning of the 2017 tax year and in columns c and d for the end of the tax year. Include cash, receivables, marketable and nonmarketable securities, depreciable assets (net of accumulated depreciation), real property, and other assets. Report all liabilities, including accounts payable, mortgages, notes payable, and other liabilities. Line 21 must equal the total assets reported on line 11.
Foreign Grantor Trust Owner Statement
Prepare a separate statement (page 3) for each U.S. owner. Include trust identification, U.S. agent status, trustee details, owner's tax year, owner identification, and service center where the U.S. owner files income tax returns. Report the gross value of the portion treated as owned by that owner on line 9 and complete the income statement with all applicable income types and expenses.
Foreign Grantor Trust Beneficiary Statement
Prepare a separate statement (page 4) for each U.S. beneficiary receiving distributions in 2017. Include trust identification, U.S. agent status, trustee details, beneficiary identification, and complete address. Describe property distributed or used by the beneficiary without compensation, including fair market value, and attach an explanation establishing that the foreign trust is treated as owned by another person.
Signature and Record Retention
The trustee must sign pages 2, 3, and 4 under penalties of perjury. Include printed title and date for each signature. If a paid preparer completes the form, the preparer must provide name, signature, date, PTIN, firm name, firm address, and EIN. The complete 2017 package includes the main Form 3520-A, all required trust documents, one Foreign Grantor Trust Owner Statement per U.S. owner, and one Foreign Grantor Trust Beneficiary Statement per U.S. beneficiary receiving distributions.
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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.
