Form 3520-A (Rev. December 2023) – 2024 Tax Year Checklist
Annual Information Return Filing Obligations
Foreign trusts with at least one U.S. owner must file Form 3520-A annually to satisfy information reporting requirements under IRC § 6048(b). This return documents the trust's income, distributions, and financial position for the tax year.
You must use the December 2023 form revision together with the December 2025 instructions for tax year 2024 and all subsequent years. Every U.S. owner and qualifying beneficiary must receive individual statements showing their allocable share of trust activity and income.
All monetary amounts must appear in U.S. dollars regardless of the trust's functional currency. The scope of required document attachments depends on whether the trust has appointed a qualified U.S. agent. Trusts without a U.S. agent must attach complete trust documents or reference prior submissions made within the last three years.
Critical Filing Requirements
Form 3520-A must be filed by the 15th day of the third month after the end of the foreign trust's tax year. A substitute Form 3520-A attached to a U.S. owner's Form 3520 follows the same due date as Form 3520.
You can sign the form electronically, but e-filing is not available, and you must submit all documents on paper. Form 3520-A is considered complete only when all required attachments are included with the filing.
Required Filing Steps
1. Verify Foreign Trust Status and U.S. Owner Identification
Enter the foreign trust's name, EIN if assigned, creation date, and full address on Part I, Line 1.
Confirm whether the trust appointed a U.S. agent under current instructions. If yes, attach the Authorization of Agent form last filed in the current year and skip Lines 2a through 2e. If no, complete the document attachment requirements described below.
2. Attach or Reference Trust Documents
If no U.S. agent is appointed, determine whether each trust document has been attached to a Form 3520-A within the prior three years. Required documents include:
- A summary of agreements
- The trust instrument
- Memoranda of wishes
- Variances
- Organizational charts
If a document was previously attached, note the prior attachment year. If not, attach the document now. All documents must be in English.
3. Complete Part II – Foreign Trust Income Statement
Enter all income and expenses from the trust's books and records for the 2024 tax year using U.S. income tax principles. Report the following income categories:
- Taxable interest from all sources
- Ordinary dividends received during the tax year
- Gross rents and royalties
- Partnership, S corporation, and fiduciary income
- Net short-term and long-term capital gains
- Ordinary gains from property sales or involuntary conversions
- Other income not included in the categories above
Deduct allowable expenses, including interest expense, foreign taxes (with attached statement), state and local taxes, amortization, depreciation, trustee and advisor fees, charitable contributions, and other expenses. Calculate net income on Line 16.
4. Report Distributions in Part II, Line 17
List the fair market value of all distributions (direct or indirect) made to any person (U.S. or foreign) during 2024. For U.S. owners and U.S. beneficiaries, provide name, TIN, distribution date, and fair market value. Attach a supporting statement if distributions exceed the space provided on the form.
5. Complete Part III – Foreign Trust Balance Sheet
Enter fair market values of all trust assets at the beginning and end of the 2024 tax year. Include cash, receivables, securities, real property, and other assets. Report total liabilities and reconcile net worth (contributions, accumulated income, other items) so that total liabilities and net worth equal total assets. Use columns (a) and (b) for the opening balance and columns (c) and (d) for the closing balance.
6. Prepare Foreign Grantor Trust Owner Statement (Page 3)
Create a separate statement on page three for each U.S. owner of the trust under IRC § 679 or similar grantor trust rules. Include trust and owner information, trustee details, the trust's tax year, and the gross value of the owned portion on Line 9.
Report all distributions and property transfers to the owner during 2024 on Line 10, with columns showing distribution dates, descriptions, fair market values, and excess of distributions over transfers. Attach a statement explaining the IRC section and facts establishing grantor trust status.
7. Prepare Statement of Foreign Trust Income Attributable to U.S. Owner (Page 4)
For each U.S. owner, allocate the trust's 2024 income and expenses by type. Include taxable interest, tax-exempt interest, ordinary dividends, qualified dividends, rents, royalties, partnership income, capital gains, ordinary gains, and other income. You must calculate the total income and deduct allocated expenses from the trust's annual activity. Sign and date the statement under penalties of perjury.
8. Prepare Foreign Grantor Trust Beneficiary Statement (Page 5)
For each U.S. beneficiary who received a distribution, loan, or use of trust property during 2024, create a separate page five statement. Report distribution date, property description, fair market value on distribution date, any property transferred back to the trust, and the excess of distributions over transfers on Line 7.
If no U.S. agent is appointed, answer whether the IRS or the beneficiary may inspect and copy the trust's books and records. Attach a statement explaining the IRC section establishing non-owner treatment.
9. Sign and Date All Required Statements
The trustee must sign Part I of Form 3520-A and each page 4 (Income Statement) under penalties of perjury. If a U.S. owner prepares a substitute Form 3520-A, the U.S. owner must sign as the preparer. A paid preparer may sign if applicable, with PTIN and firm information included.
10. Transmit Copies to U.S. Persons
Provide a copy of the Foreign Grantor Trust Owner Statement on page three and the Statement of Foreign Trust Income on page four to each U.S. owner. Provide a copy of the Foreign Grantor Trust Beneficiary Statement on page five to each U.S. beneficiary who received distributions. These statements must be furnished by the due date of Form 3520-A, which is the 15th day of the third month following the end of the trust's tax year.
11. File Form 3520-A with All Attachments
Mail the completed Form 3520-A, all trust documents or updates, separate owner statements, beneficiary statements, and supporting schedules to the Internal Revenue Service Center, P.O. Box 409101, Ogden, UT 84409. Form 3520-A cannot be filed electronically. Retain a copy for the trust's records.
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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.
