Instructions for Form 3520-A

Instructions for Form 3520-A

(Rev. December 2025)

(Use with the December 2023 revision of Form 3520-A.)

Annual Information Return of Foreign Trust With a U.S. Owner

Section references are to the Internal Revenue Code

unless otherwise noted.

Line 22 in the Instructions for Form 3520. See Penalties,

later.

Future Developments

Exceptions To Filing

For the latest information about developments related to

Form 3520-A and its instructions, such as legislation

enacted after they were published, go to IRS.gov/

Form3520A.

Reminders

Due date. Form 3520-A is due by the 15th day of the 3rd

month after the end of the foreign trust’s tax year.

However, a substitute Form 3520-A attached to a U.S

owner’s Form 3520 is due the same day as Form 3520.

See When To File, later.

Continuous-use revision. Use these instructions for tax

year 2025 and subsequent years until a superseding

revision is issued.

Tax year and statements. Enter the tax year at the top

of the first page and all statements. If the foreign trust has

adopted a fiscal tax year, enter the calendar year in which

the fiscal tax year begins on all statements.

Note: All information provided must be in English. All

amounts reported must be in U.S. currency.

General Instructions

Purpose of Form

Form 3520-A is the annual information return of a foreign

trust with at least one U.S. owner. The form provides

information about the foreign trust, its U.S. beneficiaries,

and any U.S. person who is treated as an owner of any

portion of the foreign trust under the grantor trust rules

(sections 671 through 679).

Who Must File

A foreign trust with a U.S. owner must file Form 3520-A in

order for the U.S. owner to satisfy its annual information

reporting requirements under section 6048(b). Each U.S.

person treated as an owner of any portion of a foreign

trust under the grantor trust rules (sections 671 through

679) is responsible for ensuring that the foreign trust files

Form 3520-A and furnishes the required annual

statements to its U.S. owners and U.S. beneficiaries. If a

foreign trust fails to file Form 3520-A, the U.S. owner must

complete and attach a substitute Form 3520-A for the

foreign trust to the U.S. owner’s Form 3520, Annual Return

To Report Transactions With Foreign Trusts and Receipt of

Certain Foreign Gifts, to avoid being subject to the penalty

for the foreign trust’s failure to file a Form 3520-A. See

Oct 8, 2025

Rev. Proc. 2014-55 exempts from foreign trust information

reporting certain Canadian retirement plans, including

Canadian registered retirement savings plans (RRSPs)

and Canadian registered retirement income funds

(RRIFs). For more information about whether a Canadian

retirement plan qualifies for an exemption from foreign

trust information reporting, see sections 3 and 5 of Rev.

Proc. 2014-55, 2014-44 I.R.B. 753, available at

IRS.gov/IRB/2014-44_IRB#RP-2014-55.

Rev. Proc. 2020-17 exempts from foreign trust

information reporting certain eligible individuals’

transactions with, and ownership of, certain tax-favored

foreign trusts that are established and operated

exclusively or almost exclusively to provide pension or

retirement benefits, or to provide medical, disability, or

educational benefits. For more information, see section 5

of Rev. Proc. 2020-17, 2020-12 I.R.B. 539, available at

IRS.gov/IRB/2020-12_IRB#REV-PROC-2020-17.

Proposed regulations under section 6048 exempt from

foreign trust information reporting certain eligible

individuals’ transactions with, and ownership of, certain

tax-favored foreign trusts that are established and

operated exclusively or almost exclusively to provide

pension or retirement benefits, or to provide medical,

disability, or educational benefits. You may rely on these

proposed regulations for any tax year ending after May 8,

2024, and beginning on or before the date that final

regulations are published in the Federal Register,

provided you and all related persons (within the meaning

of sections 267(b) and 707(b)(1)) apply the proposed

regulations in their entirety and in a consistent manner for

all tax years beginning with the first tax year of reliance

until the applicability date of the final regulations. For more

information, see Proposed Regulations section 1.6048-5

as published in the Federal Register at govinfo.gov/

content/pkg/FR-2024-05-08/pdf/2024-09434.pdf.

The exemptions from foreign trust information reporting

described in Rev. Proc. 2014-55, Rev. Proc. 2020-17, and

the proposed regulations under section 6048 do not affect

any reporting obligations under section 6038D or under

any other provision of the U.S. law, including the

requirement to file Financial Crimes Enforcement

(FinCEN) Form 114, Report of Foreign Bank and Financial

Accounts (FBAR), imposed by 31 U.S.C. section 5314

and the regulations thereunder. For more information, go

to IRS.gov/FBAR.

Instructions for Form 3520-A (Rev. 12-2025) Catalog Number 25096U

Department of the Treasury Internal Revenue Service www.irs.gov

When To File

The foreign trust must file Form 3520-A, including the

Foreign Grantor Trust Owner Statement (pages 3 and 4)

and the Foreign Grantor Trust Beneficiary Statement

(page 5), by the 15th day of the third month following the

end of the trust’s tax year unless an extension of time to

file is granted. The foreign trust must also provide copies

of the Foreign Grantor Trust Owner Statement (pages 3

and 4) and the Foreign Grantor Trust Beneficiary

Statement (page 5) to the U.S. owners and U.S.

beneficiaries by the due date of Form 3520-A.

If the foreign trust fails to file Form 3520-A, the U.S.

owner must file a substitute Form 3520-A, including the

Foreign Grantor Trust Owner Statement (pages 3 and 4)

and the Foreign Grantor Trust Beneficiary Statement

(page 5), along with the U.S. owner’s Form 3520, by the

Form 3520 due date. The U.S. owner must also provide

copies of the Foreign Grantor Trust Owner Statement

(pages 3 and 4) and the Foreign Grantor Trust Beneficiary

Statement (page 5) to the U.S. owners and U.S.

beneficiaries by the Form 3520 due date. See the

Instructions for Form 3520 for the due date of Form 3520.

Caution: Only a complete Form 3520-A is considered

timely filed. Form 3520-A is considered complete only if all

required attachments are included.

Extension of time to file. File Form 7004, Application for

Automatic Extension of Time To File Certain Business

Income Tax, Information, and Other Returns, using the

foreign trust’s employer identification number (EIN), to

request an extension of time to file Form 3520-A. Form

7004 must be filed by the 15th day of the 3rd month

following the end of the trust’s tax year. See Form 7004 for

additional information.

Note: An extension of time to file an income tax return

does NOT extend the time to file Form 3520-A. You MUST

file Form 7004 using the foreign trust’s EIN to request an

extension of time to file Form 3520-A.

Where To File

File Form 3520-A, including the Foreign Grantor Trust

Owner Statement (pages 3 and 4) and the Foreign

Grantor Trust Beneficiary Statement (page 5), at the

following address.

Internal Revenue Service Center

P.O. Box 409101

Ogden, UT 84409

See the Instructions for Form 3520 for where to file a

substitute Form 3520-A attached to the U.S. owner’s Form

3520.

Who Must Sign

Form 3520-A must be signed by the trustee of the foreign

trust. If the trustee is a partnership, a partner or limited

liability company (LLC) member must sign Form 3520-A. If

the trustee is a corporation, the president, vice president,

treasurer, assistant treasurer, chief accounting officer, or

any other corporate officer authorized to sign must sign

Form 3520-A. However, if Form 3520-A is filed on behalf

of a trustee that is a partnership or corporation by a

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receiver, trustee, or assignee, the fiduciary must sign the

return, instead of the partner, LLC member, or corporate

officer. A Form 3520-A signed by a receiver or trustee in

bankruptcy on behalf of a trustee that is a partnership or

corporation must be accompanied by a copy of the order

or instructions of the court authorizing signing of Form

3520-A.

A substitute Form 3520-A must be signed by the U.S.

owner. The U.S. owner’s name and taxpayer identification

number (TIN) must be provided on the “Title” line of the

signature box.

When using a paid preparer, the paid preparer must do

the following.

• Complete the required preparer information, including

their name, Preparer Tax Identification Number (PTIN),

and other identifying details.

• Sign the return in the space provided for the preparer’s

signature.

• Provide a copy of the return to the trustee or U.S. owner.

Inconsistent Treatment of Items

The U.S. beneficiary’s and U.S. owner’s tax returns must

be consistent with the Form 3520-A filed by the foreign

trust unless you report the inconsistency to the IRS. If the

U.S. beneficiaries or U.S. owners are treating items on

their tax returns differently from the way the foreign trust

treated them on its return, they must file Form 8082,

Notice of Inconsistent Treatment or Administrative

Adjustment Request (AAR). See Form 8082 for more

details.

Penalties

The U.S. owner is subject to an initial penalty equal to the

greater of $10,000 or 5% of the gross value, defined later,

of the portion of the trust’s assets treated as owned by the

U.S. person at the close of that tax year if the foreign trust

(a) fails to file a timely Form 3520-A, or (b) does not

furnish all of the information required by section 6048(b) or

includes incorrect information. See section 6677(a)

through (c).

If a foreign trust fails to file a Form 3520-A, the U.S.

owner must complete and attach a substitute Form

3520-A to the U.S. owner’s Form 3520 by the due date of

the U.S. owner’s Form 3520 (and not the due date for

Form 3520-A) in order to avoid being subject to a penalty

for the foreign trust’s failure to file a Form 3520-A. For

example, a substitute Form 3520-A that, to the best of the

U.S. owner’s ability, is completed and attached to the U.S.

owner’s Form 3520 by the due date for the Form 3520

(such as April 15 for the U.S. owners who are individuals)

is considered timely filed.

Additional penalties will be imposed if the

noncompliance continues for more than 90 days after the

IRS mails a notice of failure to comply with the required

reporting. If the IRS can determine the gross value,

defined later, of the portion of the trust’s assets treated as

owned by the U.S. person at the close of the tax year, then

the penalties will be reduced as necessary to assure that

the aggregate amount of such penalties does not exceed

the gross value of the trust. For more information, see

section 6677.

Instructions for Form 3520-A (Rev. 12-2025)

Criminal penalties may be imposed under sections

7203, 7206, and 7207 for failure to file on time and for

filing a false or fraudulent return.

services have an FMV of $20, the U.S. owner has

received a distribution of $80.

Note: If a U.S. owner of a foreign trust is subject to a 20%

penalty imposed under section 6662 for an underpayment

of tax required to be shown on a return, then such penalty

may be increased to 40% under section 6662(j) for any

portion of an underpayment that is attributable to any

transaction involving any asset with respect to which

information was required to be provided on Form 3520-A.

For more information about undisclosed foreign financial

asset understatements, see section 6662(j).

A foreign trust is any trust other than a domestic trust. A

domestic trust is any trust if:

1. A court within the United States is able to exercise

primary supervision over the administration of the trust,

and

2. One or more U.S. persons have the authority to

control all substantial decisions of the trust.

Reasonable cause. No penalties will be imposed if the

taxpayer can demonstrate that the failure to comply with

the reporting requirements was due to reasonable cause

and not willful neglect.

A grantor includes any person who creates a trust or

directly or indirectly makes a gratuitous transfer of cash or

other property to a trust. A grantor includes any person

treated as the owner of any part of a foreign trust’s assets

under sections 671 through 679, excluding section 678.

Note: The fact that a foreign country would impose

penalties for disclosing the required information is not

reasonable cause. See section 6677(d). Similarly,

reluctance on the part of a foreign fiduciary or provisions

in the trust instrument that prevent the disclosure of

required information is not reasonable cause.

Definitions

Distribution

A distribution received directly or indirectly from a foreign

trust for section 6048(c) reporting purposes is any

gratuitous transfer of money or other property from a

foreign trust, whether or not a portion of such trust is

treated as a grantor trust under the grantor trust rules of

sections 671 through 679, and without regard to whether

the recipient is designated as a beneficiary by the terms of

the trust. A distribution includes the receipt of trust corpus

and the receipt of a gift or bequest described in section

663(a).

A distribution also includes constructive transfers from

a foreign trust. For example, if a U.S. beneficiary, defined

later, or U.S. owner makes charges on a credit card that

are paid by a foreign trust or guaranteed or secured by the

assets of a foreign trust, the amount charged will be

treated as a distribution to that U.S. beneficiary or U.S.

owner by the foreign trust. Similarly, if a U.S. beneficiary or

U.S. owner writes checks on a foreign trust’s bank

account, the amount will be treated as a distribution. Also,

if a U.S. beneficiary or U.S. owner receives a payment

from a foreign trust in exchange for property transferred to

the trust or services rendered to the trust, and the fair

market value (FMV) of the payment received exceeds the

FMV of the property transferred or services rendered, the

excess will be treated as a distribution to that U.S.

beneficiary or U.S. owner. See section V of Notice 97-34,

1997-25 I.R.B. 22, available at IRS.gov/pub/irs-irbs/

irb97-25.pdf.

Example 1. If a U.S. beneficiary sells stock with an

FMV of $100 to a foreign trust and receives $150 in

exchange, the U.S. beneficiary has received a distribution

of $50.

Example 2. If a U.S. owner receives $100 from a

foreign trust for performing services for the trust, and the

Instructions for Form 3520-A (Rev. 12-2025)

Foreign Trust and Domestic Trust

Grantor

Note: If a partnership or corporation makes a gratuitous

transfer to a trust, the partners or shareholders are

generally treated as the grantors of the trust, unless the

partnership or corporation made the transfer for a

business purpose of the partnership or corporation.

If a trust makes a gratuitous transfer to another trust,

the grantor of the transferor trust is treated as the grantor

of the transferee trust, except that if a person with a

general power of appointment over the transferor trust

exercises that power in favor of another trust, such person

is treated as the grantor of the transferee trust, even if the

grantor of the transferor trust is treated as the owner of the

transferor trust.

Grantor Trust

A grantor trust is any trust to the extent that the assets of

the trust are treated as owned by a person other than the

trust. See the grantor trust rules in sections 671 through

679. A part of the trust may be treated as a grantor trust to

the extent that only a portion of the trust assets are owned

by a person other than the trust.

Note: Under the HIRE Act, effective after March 18, 2010,

if a foreign trust directly or indirectly loans cash or

marketable securities to a U.S. person who does not repay

the loan at a market rate of interest, or allows a U.S.

person to use trust property without paying FMV within a

reasonable period of time, the trust will be treated as

having a U.S. beneficiary and is therefore treated as a

grantor trust under the grantor trust rules. See section

679.

Gross Value

Gross value is the value of property as determined under

section 2512 and its regulations, without regard to any

prohibitions or restrictions on a person’s interest in the

property. See section VII of Notice 97-34. Although formal

appraisals are generally not required, you should keep

contemporaneous records of how you arrived at your

good faith estimate.

Nongrantor Trust

A nongrantor trust is any trust to the extent that the assets

of the trust are not treated as owned by a person other

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than the trust under the grantor trust rules in sections 671

through 679. Thus, a nongrantor trust is treated as a

taxable entity. A trust may be treated as a nongrantor trust

with respect to only a portion of the trust assets. See

Grantor Trust, earlier.

Owner

An owner of a foreign trust is the person that is treated as

owning any of the assets of a foreign trust under the

grantor trust rules.

Property

AUTHORIZATION OF AGENT

[ Name of foreign trust ] hereby expressly authorizes [ name of

U.S. agent ] to act as its agent solely for purposes of sections

7602, 7603, and 7604 of the Internal Revenue Code with respect to

any request to examine records or produce testimony related to the

proper treatment of amounts required to be taken into account

under the rules of section 6048(b)(2)(A) or to any summons for such

records or testimony. I certify that I have the authority to execute

this authorization of agent to act on behalf of [ name of foreign

trust ].

Signature of trustee

(or other authorized person)

Property means any property, whether tangible or

intangible, including cash.

Your Name (type or print)

U.S. Agent

Taxpayer Identification Number (if any)

A U.S. agent is a U.S. person, defined later, that has a

binding contract with a foreign trust that allows the U.S.

person to act as the trust’s authorized U.S. agent, in

applying sections 7602, 7603, and 7604 with respect to:

• Any request by the IRS to examine records or produce

testimony related to the proper U.S. tax treatment of

amounts distributed, or required to be taken into account

under the grantor trust rules, with respect to a foreign

trust; or

• Any summons by the IRS for such records or testimony.

A U.S. grantor, a U.S. beneficiary, or a domestic

corporation controlled by the grantor or beneficiary may

act as a U.S. agent. However, a foreign trust will not be

treated as having a U.S. agent unless the U.S. agent’s

name, address, and TIN are entered on lines 3a through

3g of Part I of Form 3520-A. See Taxpayer identification

numbers (TINs), later.

If a foreign trust with a U.S. owner does not have a U.S.

agent, the IRS may redetermine the amounts required to

be taken into account with respect to the foreign trust by

the U.S. owner. See section 6048(b)(2). In order to avoid

this, a U.S. owner of a foreign trust should ensure that the

foreign trust appoints a U.S. person to act as the foreign

trust’s limited agent for purposes of applying sections

7602, 7603, and 7604. The agency relationship must be

established by the time the U.S. person files Form 3520-A

for the relevant tax year and must continue as long as the

statute of limitations remains open for the relevant tax

year.

In order to authorize a U.S. person to act as an agent

under section 6048(b), the trust and the agent must enter

into a binding agreement substantially in the format that

follows.

(title)

(date)

Address

[ Name of agent ] accepts this appointment to act as agent

for [ name of foreign trust ] for the above purpose. I certify that I

have the authority to execute this authorization of agent to act on

behalf of [ name of foreign trust ] and agree to accept service of

process for the above purposes.

Signature of agent

(title)

(date)

Your Name (type or print)

Taxpayer Identification Number (if any)

Address

Caution: Do not enter a PTIN on the Authorization of

Agent form.

If the U.S. person’s responsibility as an agent of the

foreign trust is terminated for any reason (for example,

resignation, liquidation, or death), the U.S. owner of the

foreign trust must make sure the foreign trust files an

amended Form 3520-A with the IRS within 90 days. See

section IV.B of Notice 97-34.

U.S. Beneficiary

A U.S. beneficiary generally includes any U.S. person that

could possibly benefit (directly or indirectly) from the trust

(including an amended trust) at any time, whether or not

the person is designated in the trust instrument as a

beneficiary and whether or not the person can receive a

distribution from the trust in the current year. In addition, a

U.S. beneficiary includes:

• A foreign corporation that is a controlled foreign

corporation (as defined in section 957(a)),

• A foreign partnership if a U.S. person is a partner of the

partnership, and

• A foreign estate or trust if the estate or trust has a U.S.

beneficiary. See section II of Notice 97-34 and the

regulations under section 679 for additional information.

Foreign trust treated as having a U.S. beneficiary. In

general, if a U.S. person, directly or indirectly, transfers

property to a foreign trust (other than a deferred

compensation or charitable trust described in section

6048(a)(3)(B)(ii)), the foreign trust will be treated as

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Instructions for Form 3520-A (Rev. 12-2025)

having a U.S. beneficiary unless the terms of the trust

instrument specifically prohibit any distribution of income

or corpus to a U.S. person at any time, even after the

death of the U.S. transferor or any event terminating the

trust, and the trust cannot be amended or revised to allow

such a distribution. For these purposes, an amount will be

treated as accumulated for the benefit of a U.S. person

even if the U.S. person’s interest in the trust is contingent

on a future event and regardless of whether anything is

actually distributed to a U.S. person during that tax year.

Special rule in case of discretion to identify

beneficiaries. For purposes of the general rule above, if

any person has the discretion of making a distribution

from the trust to, or for the benefit of, any person, the trust

will be treated as having a beneficiary who is a U.S.

person, unless the terms of the trust specifically identify

the class of persons to whom such distributions may be

made, and none of those persons are U.S. persons during

the tax year.

Certain agreements and understandings treated as

terms of the trust. For purposes of the general rule

above, if any U.S. person who directly or indirectly

transfers property to the trust is directly or indirectly

involved in any agreement or understanding (whether

written, oral, or otherwise) that may result in the income or

corpus of the trust being paid or accumulated to, or for the

benefit of, a U.S. person, such agreement or

understanding will be treated as a term of the trust.

Certain loans or uncompensated use of trust

property. If a foreign trust is not already treated as having

a U.S. beneficiary under the rules described above, the

trust will be treated as having a U.S. beneficiary if, after

March 18, 2010, either:

• The foreign trust loans cash or marketable securities,

directly or indirectly, to a U.S. person and the U.S. person

does not repay the loan at a market rate of interest within a

reasonable period of time; or

• A U.S. person, directly or indirectly, uses property that is

owned by the foreign trust and does not pay FMV of the

use of such property within a reasonable period of time.

Presumption that foreign trust has U.S. beneficiary. If

a U.S. person, directly or indirectly, transfers property to a

foreign trust (other than a deferred compensation or

charitable trust described in section 6048(a)(3)(B)(ii)), the

IRS may treat such trust as having a U.S. beneficiary for

purposes of applying section 679(d) to such transfer if the

IRS requests information with respect to the transfer and

the U.S. person fails to demonstrate to the satisfaction of

the IRS that no portion of the income or corpus of the trust

may ever be paid to or accumulated for the benefit of a

U.S. person.

U.S. Person

A U.S. person is:

• A citizen or resident of the United States, including dual

residents who claim the benefits under an income tax

treaty;

• A domestic partnership;

• A domestic corporation;

• Any estate (other than a foreign estate, within the

meaning of section 7701(a)(31)(A)); and

• Any domestic trust (defined earlier).

Instructions for Form 3520-A (Rev. 12-2025)

For guidance on determining resident alien status, go

to Pub. 519, U.S. Tax Guide for Aliens.

Specific Instructions

Period Covered

For calendar-year filers, fill in the “calendar year” space at

the top of the form. For fiscal-year filers, fill in the “tax year

beginning” and “ending” spaces at the top of the form.

Initial Return, Final Return, Amended

Return, Extension Filed, Substitute

Form 3520-A

Initial return. If this is the foreign trust’s first return, check

the “Initial return” box.

Final return. If the foreign trust ceases to exist, check the

“Final return” box.

Amended return. If this Form 3520-A is filed to amend a

previously filed Form 3520-A, check the “Amended return”

box.

Extension filed. If the Form 7004 was timely filed to

request an extension for the Form 3520-A, check the

“Extension filed” box.

Substitute Form 3520-A. If you are a U.S. owner of the

foreign trust filing a substitute Form 3520-A and attaching

it to your Form 3520, check the “Substitute Form 3520-A”

box.

Excepted Specified Foreign Financial

Assets Reported

Check the box only if a U.S. person treated as the owner

of any portion of the trust under the grantor trust rules also

files Form 8938, Statement of Specified Foreign Financial

Assets, for the tax year and includes this form in the total

number of Forms 3520-A reported on line 16 of Part IV,

Excepted Specified Foreign Financial Assets, of Form

8938. For more information, see the Instructions for Form

8938, generally, and in particular, Duplicative reporting

and the specific instructions for Part IV.

Part I—General Information

Taxpayer identification numbers (TINs). Use social

security numbers (SSNs) or individual taxpayer

identification numbers (ITINs) to identify individuals. Use

EINs to identify estates, trusts, partnerships, and

corporations. Don’t use an SSN in place of an EIN.

Applying for an EIN. If the foreign trust doesn’t have an

EIN, the foreign trust may apply for one online at IRS.gov/

EIN. If the foreign trust’s principal place of business is

outside the United States or its territories, the foreign trust

can apply for an EIN by phone at 267-941-1099. See

International EIN applicants under Other ways to apply for

an EIN at IRS.gov/EIN.

Caution: Do not enter a PTIN in any entry space on Form

3520-A other than the entry space for “PTIN” at the bottom

of page 1 of the form.

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Address. Include the room, suite, or other unit number

after the street address. If the post office does not deliver

mail to the street address and the U.S. person has a P.O.

box, show the box number instead.

Foreign address. Do not abbreviate the country name.

Line 1b. Enter the EIN of the foreign trust. Do not enter

an SSN or ITIN. Only an EIN should be used to identify

the foreign trust.

Line 2. Check “Yes” if the foreign trust appointed a U.S.

agent and enter the year the Authorization of Agent form

was last attached. See U.S. Agent, earlier, for the

Authorization of Agent form.

The Authorization of Agent form should be attached

every 3 years unless there has been a change, and if so, it

should be attached in the year with respect to which the

change relates.

Check “No” if the foreign trust did not appoint a U.S.

agent, and attach the following documents to Form

3520-A.

• A summary of the terms of the trust that includes a

summary of any oral agreements or understandings you

have with the trustee, whether or not legally enforceable.

• A copy of all trust documents (and any revisions),

including the trust instrument, any memoranda of wishes

prepared by the trustees summarizing the settlor’s wishes,

any letter of wishes prepared by the settlor summarizing

his or her wishes, and any similar documents.

• A copy of the trust’s organizational chart, including

ownership structure and percentage of ownership.

Note: If these documents have been attached to a Form

3520-A filed within the previous 3 years, attach only

relevant updates.

Lines 3a through 3g. Enter the name, TIN, and address

of the U.S. agent appointed. See U.S. Agent, earlier.

Line 5. Enter the number of Foreign Grantor Trust Owner

Statements (pages 3 and 4) included with this Form

3520-A.

Line 6. Enter the number of Foreign Grantor Trust

Beneficiary Statements (page 5) included with this Form

3520-A.

Sign here. The trustee of the foreign trust must sign the

Form 3520-A; however, if the U.S. owner of the foreign

trust is filing a substitute Form 3520-A, the U.S. owner

must sign. See Who Must Sign, earlier.

Part II—Foreign Trust Income

Statement

Include all income from U.S. and non-U.S. sources. This

financial statement must reasonably reflect the trust’s

income under U.S. income tax principles.

Income

Line 1. Interest. Report all taxable interest income that

was received during the tax year. Examples of taxable

interest include, but are not limited to, interest from the

following.

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• Accounts (including certificates of deposit and money

market accounts) with banks, credit unions, and thrift

institutions.

• Notes, loans, and mortgages.

• U.S. Treasury bills, notes, and bonds.

• U.S. savings bonds.

• Original issue discount.

• Income received as a regular interest holder of a real

estate mortgage investment conduit (REMIC).

For taxable bonds acquired after 1987, amortizable

bond premium is treated as an offset to the interest

income instead of as a separate interest deduction. See

Pub. 550, Investment Income and Expenses.

Line 2. Dividends. Report all ordinary dividends

received during the tax year.

Note: Report capital gain distributions on Line 5. Capital

gains (losses) of this section.

Line 4. Income (loss) from partnerships, fiduciaries,

etc. Enter the trust’s share of income or (losses) from

partnerships, S corporations, estates, other trusts, and

REMICs.

If the trust received a Schedule K-1 from a partnership,

S corporation, or other flow-through entity, use the

corresponding lines on Form 3520-A to report the interest,

dividends, capital gains, etc., from the flow-through entity.

Line 5. Capital gains (losses). For capital gains or

(losses) attributable to a U.S. owner, use Schedule D

(corporate or individual, whichever applies) and Form

8949, Sales and Other Dispositions of Capital Assets, if

applicable.

Line 6. Ordinary gains (losses). Enter the ordinary gain

or (loss) from the sale or exchange of property other than

capital assets and also from involuntary conversions

(other than casualty or theft).

Line 7. Other income. Enter other items of income not

included on lines 1 through 6. List the types and amounts

on an attached statement if the trust has more than one

item.

Items to be reported on line 7 include any part of a total

distribution shown on Form 1099-R, Distributions From

Pensions, Annuities, Retirement or Profit-Sharing Plans,

IRAs, Insurance Contracts, etc., that is treated as ordinary

income. For more information, see the instructions for

Form 4972, Tax on Lump-Sum Distributions.

Expenses

Line 9. Interest expense. Enter the amount of interest

(subject to limitations) paid or incurred by the trust on

amounts borrowed by the trust, or on debt acquired by the

trust, that is not reported elsewhere in Part II.

If the proceeds of a loan were used for more than one

purpose (for example, to purchase a portfolio investment

and to acquire an interest in a passive activity), the

fiduciary must make an interest allocation according to the

rules in Temporary Regulations section 1.163-8T.

Do not include interest paid on indebtedness incurred

or continued to purchase or carry obligations on which the

interest is wholly exempt from income tax.

Instructions for Form 3520-A (Rev. 12-2025)

Line 10a. Foreign taxes. A foreign tax includes only a

tax imposed by the authority of a foreign country.

Line 10b. State and local taxes. Enter any deductible

state and local income or real property taxes paid or

incurred during the tax year that are not reported

elsewhere in Part II.

Do not deduct on line 10b or on any other line of Part II:

• Federal income taxes;

• Estate, inheritance, legacy, succession, and gift taxes;

or

• Federal duties and excise taxes.

Line 11. Amortization and depreciation (depletion). A

reasonable amount is allowed as a depreciation deduction

for the exhaustion, wear, and tear of:

• Property used in a trade or business, or

• Property held for the production of income.

Line 12. Trustee and advisor fees. Enter the deductible

fees paid or incurred to the fiduciary for administering the

trust during the tax year.

Line 13. Charitable contributions. Generally, any part

of the income reported on line 8 that is paid (or treated as

paid) during the tax year for a charitable purpose specified

in section 170(c) is allowed as a deduction. It is not

necessary that the charitable organization be created or

organized in the United States.

Line 14. Other expenses. Enter other items of expense

not listed on lines 9 through 13. List the type and amount

on an attached statement if the trust has more than one

item.

Line 17a. FMV of total distributions. Attach a

statement that provides the following information

concerning the transfer.

1. Name, U.S. TIN (if any), and country of organization

or residence of the person to whom the property was

transferred.

2. A general description of the transfer, and any

broader transaction of which it forms a part, including a

chronology of the transfers involved and an identification

of the other parties to the transaction to the extent known.

3. A description of the property transferred, including

the estimated FMV and the adjusted basis of the property.

4. A description of the consideration received by the

trust, including its estimated FMV, and for stock or

securities, the class or type, amount, and characteristics

of the interest received. If no consideration was received

by the trust, indicate whether the trust or a U.S. owner

exercises any powers over the entity to which the property

was transferred (including a description of such powers),

and identify the name, U.S. TIN (if any), and country of

organization or residence of all beneficial owners of such

entity.

5. To the extent known, a description of any

subsequent transfer of the property, including the name,

U.S. TIN (if any), and country of organization or residence

of the person to whom the property was subsequently

transferred.

(if any), and country of organization of all entities in which

the trust has an ownership interest, including an

ownership chart showing the trust’s position in the chain of

ownership and the percentages of ownership.

Note: The term “person” includes an individual or an

entity, whether U.S. or foreign. See the definition of U.S.

person, earlier. A foreign person is an individual or entity

that is not a U.S. person.

Lines 17b and 17c. Distributions to U.S. owners and

U.S. beneficiaries. Separately list the total amount of

distributions (including the uncompensated use of trust

property) to each U.S. owner and U.S. beneficiary. List the

full name, TIN, date of distribution, and FMV on the date

of distribution (dollar amount) for each U.S. owner and

U.S. beneficiary who receives a distribution. If more space

is needed, attach a statement.

Prepare a separate Foreign Grantor Trust Owner

Statement (see below) or Foreign Grantor Trust

Beneficiary Statement (see below) for each U.S. owner

or for each U.S. beneficiary who receives a distribution

from the trust.

Part III—Foreign Trust Balance Sheet

List all assets and liabilities of the trust, including those

assets and liabilities attributable to the portion(s) of the

trust (if any) not treated as owned by a U.S. person.

The balance sheet should reflect FMV. Include

certificates of deposit as cash on line 1.

For purposes of completing Part III, it is not necessary

or required to reconcile any differences between the book

and tax basis of assets and liabilities.

Line 18. Accumulated trust income. Include the total

amount of trust income accumulated and not distributed.

Foreign Grantor Trust Owner

Statement

Caution: On the top of each statement, fill in the tax year.

If the foreign trust has adopted a fiscal tax year, use the

calendar year in which the fiscal tax year begins.

A copy of this statement (pages 3 and 4 of Form

3520-A) must be (a) furnished to each U.S. person who is

treated as an owner of the foreign trust under the grantor

trust rules, and (b) included with this Form 3520-A. The

statement must be furnished to each U.S. owner no later

than the 15th day of the 3rd month following the end of the

trust’s tax year, or later if an extension of time to file is

granted, or if filing a substitute Form 3520-A. See When

and Where To File, earlier.

TINs and addresses. See the instructions for Part I,

earlier, for information on entering TINs and addresses.

Line 8. Trust documents. If the trust did not appoint a

U.S. agent, list the documents attached to the current year

Form 3520-A and those attached to a Form 3520-A filed

within the last 3 years. Specify the years the documents

were attached. See Line 2 under Part I, earlier, for a list of

documents the trust is required to attach to Form 3520-A.

The statement must also contain a description of the

trust ownership structure setting forth the name, U.S. TIN

Instructions for Form 3520-A (Rev. 12-2025)

7

Statement of Foreign Trust Income Attributable

to U.S. Owner

Caution: On the top of each statement, fill in the tax year.

For fiscal-year filers, use the year in which your fiscal tax

year begins.

The amounts on the statement must include the portion

of income reported by the foreign trust deemed

attributable to the U.S. owner.

The foreign trust may need to furnish to the U.S. owner

additional information, including applicable statements, to

ensure that the owner accurately reports income and

expenses on the owner’s U.S. income tax return.

Foreign Grantor Trust Beneficiary

Statement

Caution: On the top of each statement, fill in the tax year.

If the foreign trust has adopted a fiscal tax year, use the

calendar year in which the fiscal tax year begins.

A copy of this statement (page 5 of Form 3520-A) must

be (a) furnished to each U.S. beneficiary who receives a

distribution, directly or indirectly, from the foreign trust

during the tax year; and (b) included with this Form

3520-A. See the definitions for U.S. beneficiary and

distribution provided earlier in these instructions.

Exception. Do not complete this statement for a U.S.

person for any portion of the trust of which that U.S.

person is treated as the owner; instead, complete the

Foreign Grantor Trust Owner Statement for that U.S.

person (as described earlier).

The statement must be furnished to the U.S.

beneficiary no later than the 15th day of the 3rd month

following the end of the trust’s tax year, or later if an

extension of time to file is granted, or if filing a substitute

Form 3520-A. See When and Where To File, earlier.

TINs and addresses. See the instructions for Part I,

earlier, for information on entering TINs and addresses.

8

Paperwork Reduction Act Notice. We ask for the

information on this form to carry out the Internal Revenue

laws of the United States. You are required to give us the

information. We need it to ensure that you are complying

with these laws and to allow us to figure and collect the

right amount of tax.

You are not required to provide the information

requested on a form that is subject to the Paperwork

Reduction Act unless the form displays a valid OMB

control number. Books or records relating to a form or its

instructions must be retained for as long as their contents

may become material in the administration of any Internal

Revenue law.

The time needed to complete and file the form will vary

depending on individual circumstances. The estimated

average time is:

Recordkeeping . . . . . . . . . . . . . . . . .

37 hr., 18 min.

Learning about the law or the

form . . . . . . . . . . . . . . . . . . . . . . . . .

2 hr., 40 min.

Preparing and sending the form to

the IRS . . . . . . . . . . . . . . . . . . . . . . .

3 hr., 24 min.

If you have comments concerning the accuracy of

these time estimates or suggestions for making this form

simpler, we would be happy to hear from you. You can

send us comments through IRS.gov/FormComments. Or

you can send your comments to Internal Revenue Service,

Tax Forms and Publications Division, 1111 Constitution

Ave. NW, IR-6526, Washington, DC 20224. Do not send

the form to this office. Instead, see When and Where To

File, earlier.

Instructions for Form 3520-A (Rev. 12-2025)