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TXCPA Committee Has Significant Concerns with Forms 3520 and 3520-A Penalty Assessments

Today, TXCPA’s Federal Tax Policy (FTP) Committee responded to the IRS public comments period on forms related to certain foreign trust transactions. The committee is concerned that the IRS’ current practice of automatically assessing, enforcing and collecting excessive penalties—which are a minimum of $10,000 per year—on late or amended reporting is contrary to Congressional intent. Taxpayers should be given a fair and meaningful reasonable cause review before these penalties are imposed. The committee urges the IRS to substantially revise its procedures for reviewing reasonable cause statements.

Read FTP letter.


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