Updated October 18, 2026. Quick answer: Form 3520-A is the annual information return of a foreign trust that has at least one U.S. owner. The trust files it, and a U.S. owner who finds the trust has not filed attaches a substitute to his or her own Form 3520. Part I covers the trust’s general information; Parts II and III carry the income statement and balance sheet, and pages 3 to 5 hold the owner and beneficiary statements.
What this part is for
The instructions describe the 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 files: “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 the trust does not: “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”. That return is described in the Form 3520 guide and on Form 3520 Part II. 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.”
The lines, one by one
Part I, General Information, is on page 1. The form’s lines and the matching instructions read as follows.
| Line | What the form says |
|---|---|
| Heading boxes | “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” |
| Final return | “If the foreign trust ceases to exist, check the” |
| Amended return | “If this Form 3520-A is filed to amend a previously filed Form 3520-A, check the” |
| Extension filed | “If the Form 7004 was timely filed to request an extension for the Form 3520-A, check the” |
| Substitute | “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” |
| Excepted assets box | “Check if any excepted specified foreign financial assets are reported on this form.” |
| 1a and 1b | “Name of foreign trust b Employer identification number (EIN)” |
| 1c and 1d | “Number, street, and room or suite no. If a P.O. box, see instructions.” “Date foreign trust was created” |
| 1e to 1h | “City or town f State or province g ZIP or foreign postal code h Country” |
| 2 | “Did the foreign trust appoint a U.S. agent (defined in the instructions) who can provide the IRS with all the relevant trust information?” |
| 2, if Yes | “enter the year the Authorization of Agent form was last attached and skip lines 2a through 2e and go to line 3.” |
| 2, if No | “you are required to attach a copy of all trust documents as indicated below.” The list: “Summary of all written and oral agreements and understandings relating to the trust”; “The trust instrument”; “Memoranda or letters of wishes”; “Subsequent variances to original trust documents”; “Organizational chart and other trust documents” |
| 3a to 3g | “Name of U.S. agent b Taxpayer identification number (TIN)” “Enter the name, TIN, and address of the U.S. agent appointed.” |
| 4a to 4g | “Name of trustee b TIN, if any” |
| 5 | “Enter the number of Foreign Grantor Trust Owner Statements (pages 3 and 4) included with this Form 3520-A” |
| 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.” |
The trust’s tax identification numbers follow a rule: “Use EINs to identify estates, trusts, partnerships, and corporations.” “Don’t use an SSN in place of an EIN.” “Only an EIN should be used to identify the foreign trust.”
Where the number comes from
Part I has no calculation. The Excepted assets box ties to Form 8938: “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”. The other pages are covered separately: the income statement and balance sheet are on Form 3520-A Parts II and III.
Pages 3 to 5 hold statements. On the owner statement: “Trustee (or U.S. owner if a substitute Form 3520-A) must prepare a separate statement for each U.S. owner and include a copy of each statement with Form 3520-A.” “U.S. owner must attach a copy of its statement to Form 3520.” The income statement page says “Report each item on the proper form or schedule of your tax return.” On the beneficiary statement: “Each U.S. beneficiary must attach a copy of its statement to its Form 3520.”
Where it goes next
The filing deadline is tied to the trust’s year: “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.”
Extensions work differently from income tax extensions: “Note: An extension of time to file an income tax return does NOT extend the time to file Form 3520-A.” “Only a complete Form 3520-A is considered timely filed.”
The trust’s own return must match yours: “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.” See Form 1040 and the broader context in Form 3520 for a foreign inheritance.
Numbers printed in the Form 3520-A instructions
| Where | What the IRS prints |
|---|---|
| Penalty | “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” |
| Continued noncompliance | “more than 90 days after the IRS mails a notice of failure to comply with the required reporting” |
| Amended form | “must make sure the foreign trust files an amended Form 3520-A with the IRS within 90 days” |
| Attachments | “attached to a Form 3520-A filed within the previous 3 years, attach only relevant updates” |
These figures come from the penalty, termination and attachment text. Nothing here is computed for you.
Edition and line numbers
This page reads Form 3520-A (Rev. December 2023) and the Instructions for Form 3520-A (Rev. December 2025), which the IRS says to use with the December 2023 revision of the form; these are the current files irs.gov served on 2026-10-18. Check the edition printed on your own form and use that edition’s line numbers.
Common mistakes
- Assuming a personal income tax extension covers the trust. The instructions say “An extension of time to file an income tax return does NOT extend the time to file Form 3520-A.”
- Entering a Social Security number for the trust. The instructions say “Do not enter an SSN or ITIN.”
- Checking No on line 2 without the documents. The instructions say “if the foreign trust did not appoint a U.S. agent, and attach the following documents to Form 3520-A.”
Related: Form 3520, Form 3520 for a foreign inheritance, Form 8938, and Form 1040.
Sources
- Form 3520-A (Rev. December 2023), Annual Information Return of Foreign Trust With a U.S. Owner: https://www.irs.gov/pub/irs-pdf/f3520a.pdf
- Instructions for Form 3520-A (Rev. December 2025): https://www.irs.gov/pub/irs-pdf/i3520a.pdf
- IRS: About Form 3520-A: https://www.irs.gov/forms-pubs/about-form-3520-a
Read from the IRS documents linked above on October 18, 2026. General information, not tax advice. Your own facts decide the outcome, and a preparer, the account provider or the IRS is the right place to confirm anything consequential.