IRS Form
IRS Form 3520-A: Annual Return for a Foreign Trust
IRS Form 3520-A is the annual information return for a foreign trust that has a US owner. It reports the trust's activity and pairs with Form 3520, which covers the US person's own transactions with the trust and foreign gifts.
Overview
What Form 3520-A is
Form 3520-A is the annual information return for a foreign trust that is treated as owned by a US person. It reports the trust’s income, distributions, and financial position for the year, and it produces statements that flow through to the US owner and to beneficiaries.
Where Form 3520 looks at the arrangement from the individual’s perspective, Form 3520-A looks at it from the trust’s perspective. It is the trust-level counterpart in a two-part reporting structure.
Why it exists
When a foreign trust is treated as owned by a US person under the grantor trust rules, the income of that trust is generally attributed to the owner. For the US tax system to apply that treatment properly, it needs a clear annual picture of what the trust did.
Form 3520-A provides that picture. It ensures the trust’s annual activity is visible and that the US owner and beneficiaries receive the information they need to report their own positions accurately, complementing the individual-level disclosure on Form 3520.
Who generally files it
- Foreign trusts that have a US owner under the grantor trust rules.
- US owners who must ensure the annual trust return is filed on time.
- US owners who may complete a substitute return where the trust does not file.
- Arrangements where trust-level and owner-level reporting must be coordinated.
Process
How it fits into the filing process
Confirm US-owner status
Establish whether the foreign trust is treated as owned by a US person, which triggers this annual return.
Gather trust-level data
Assemble the trust’s income, distributions, and balance sheet information for the year.
Produce owner and beneficiary statements
The return generates statements that the US owner and beneficiaries use for their own reporting.
Coordinate with Form 3520
The trust-level return is prepared in step with the individual-level Form 3520 for a complete picture.
Key facts
- Form type
- Annual information return
- Covers
- A foreign trust with a US owner
- Paired with
- Form 3520 (individual-level reporting)
- Perspective
- Trust level rather than individual level
How it relates to other filings
Form 3520-A is the natural companion to Form 3520. One reports the trust’s annual activity and the other reports the US person’s transactions with the trust. Together they sit within the broader landscape of foreign asset reporting that supports the main US individual tax return for taxpayers with cross-border connections.
Frequently asked questions
Form 3520-A is the annual information return for a foreign trust that has a US owner. It reports the trust’s activity and provides statements to the US owner and beneficiaries.
It exists so the IRS can see the annual activity of a foreign trust treated as owned by a US person, complementing the individual-level reporting on Form 3520.
The foreign trust itself is generally responsible for filing, but a US owner may need to ensure it is filed and may take steps to complete it where the trust does not.
They are a pair. Form 3520-A reports the trust’s annual activity, while Form 3520 reports the US person’s transactions with the trust and other foreign gifts.
US owner of a foreign trust?
The pairing of Form 3520 and Form 3520-A can be confusing. We can help you understand the annual reporting obligations.