Serbinski Accounting Firms

As a Canadian citizen who came down to the U.S. many years ago and became a USC 10 years ago, IMO, another good reason to get your Canadian citizen is so you can vote and take part in the political process. Personally, I don't think guests of a country have a (moral) right to criticize the governmen...

The Non-U.S. Resident Streamline Procedure you're referring to has been in place since 2012. The newer one for U.S. residents went into effect in 2014. I'm not a professional, but my guess is that if your FBAR delinquent accounts were jointly held, then you would have to backfile the FBARs jointly. ...

Sorry, the quote got cut off above: Line 2b(2). A reference ID number is required on line 2b(2) only in cases where the foreign trust has no employer identification number, EIN. However, filers are permitted to enter both an EIN on line 2b(1) and a reference ID number on line 2b(2). If applicable, e...

The IRS form 3520 instructions are pretty clear: Line 2b(2). A reference ID number is required on line 2b(2) only in cases where the foreign trust has no employer identification number, EIN. However, filers are permitted to enter both an EIN on line 2b(1) and a reference ID number on line 2b(2). If ...

Buddy: "The 3520 instructions state: “In general, Form 3520 is due on the date that your income tax is due, including extensions.â€￾ i.e. April 15. However, that’s only “in generalâ€￾. The filing deadline for 3520-A is March 15th, and since, in the case of a TFSA “grantor trustâ€￾, the only 3520-A filed will be the one attached to your 3520, it seems to follow implicitly, if not explicitly, that the 3520 with its attached 3520-A must be filed by March 15th. If you are tempted to think otherwise, study the ominous conclusion of 3520, Part II, #22: “See instructions for information on penaltiesâ€￾, which information, in the case of 3520-A, will include: “criminal penalties . . . for failure to file on timeâ€￾.

The trust institution isn’t sending the 3520-A, you are - attached to your 3520. Unless, and only if, a Form 7004 extension has been obtained, it is prudent to assume that the combined 3520/3520-A required filing deadline is not April 15, but March 15."

I think you are potentially adding an unnecessary reason for people to be even more paranoid than they already are when it comes to the already-daunting offshore forms and due-date requirements.

When it comes to grantor trust situation where both a 3520a and 3250 are required, whether it be TFSAs, RESPs etc., nowhere does the IRS require that Form 3520 be attached to the 3520a such that if the 3520a has to be filed by March 15, then so must the 3520. In the typical situation where the 3520 is due on the date of one's tax return, it is discretionary whether one files both forms by March 15, while it is mandatory that the 3520a is filed by March 15 and the 3520 by April 15 (the 3520 must have the Owner statement attached to it from the 3520a and also the Benefiiciary statement, if applicable). I have yet to read anywhere that the 3520 must be filed by March 15.

Personally, I keep my tax returns for at least 10 years. I've had FBAR-related tax returns since 2011. I will keep those indefinitely. Fwiw: These aren't professional recommendations; they're just mine.

The title of your post unfortunately implies that the TFSA hereafter need not be treated as a trust just because Max Reed says so. Actually, it is an excellent article when it comes to arguing why the TFSA shouldn't be treated as a trust. In fact, it sounds very much like what a lawyer might put bef...

I know where you are going, but the IRS doesn't care: Income from the trust is income from the trust & a 3250 will be required until there is none.

TFSAs and the Roth IRA have a number of similarities, but are different enough that I would not expect any defferential treatment of TFSAs by the IRS as long as that is true. And, given the present U.S. Federal financial situation (deficit & debt), I would not expect to see any changes to the U....

The IRS Instructions for the filing dates of the 3520A and 3520 are pretty explicit: 3520A: "File a complete Form 3520-A with the IRS Service Center by the 15th day of the 3rd month after the end of the trust's tax year" (which would be March 15 for year-end 12/31/14 filers). 3520: "I...

The deadline for the 3520 (not the 3520a) is Apr.15.

The deadline is Mar.15 regardless.

My strictly amateurish guess would be Line 21.

Perhaps even more important (given the potential penalties): Has your son filed the 2014 3520 form with the 2014 Foreign Grantor Trust Beneficiary Statement from your 3520A form?

cnytax: 'My first instinct is that it is probably worthless for crossborder situations given that most tax "experts" and preparers seem to know very little about this and I assume Audit Defense would be no different.' Trust your instinct. :) I wouldn't even be surprised if there is a 'smal...

Let's put this into context. Someone comes into this forum 2 weeks before April 15 and expects someone (in this case, nelsona) to sort out a complex international tax issue and then gets upset because the answers are not as detailed as one would get spending at least 2 hours with an international ta...