[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-304764-105":53,"doc-detail-304764-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","aicpa-comments-on-form-3520-a-and-form-3520-irs-filing-recommendations","AICPA Comments on Form 3520-A and Form 3520 - IRS Filing Recommendations","","Letter from the American Institute of Certified Public Accountants (AICPA) responding to an IRS request for comments on Form 3520-A and, by close linkage, Form 3520. The AICPA urges exempting Canadian RRSPs and RESPs (and their U.S. owners) from related filing requirements, creating a dedicated worksheet for foreign trust distributions, revising Form 3520-A due dates to April 15 with extensions, and adopting a consistent method for filing prior-year Forms 3520 and 3520-A to improve compliance.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/aicpa-comments-on-form-3520-a-and-form-3520-irs-filing-recommendations/304764/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/aicpa-comments-on-form-3520-a-and-form-3520-irs-filing-recommendations/304764.png","ImageObject",442,249,{"name":88,"@type":89},"Finn","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-09-27","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":79},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Why does the AICPA also comment on Form 3520 when the IRS requested comments on Form 3520-A?","Question",{"text":108,"@type":109},"Because Form 3520 is closely linked to Form 3520-A, the AICPA provides comments on both forms to address related filing and reporting obligations.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What does the AICPA urge regarding Canadian RRSPs and RESPs?",{"text":113,"@type":109},"The AICPA urges exempting Canadian RRSPs and RESPs from Form 3520-A filing requirements and exempting their U.S. owners from Form 3520 filing requirements for reporting transfers to RRSPs and RESPs.",{"name":115,"@type":106,"acceptedAnswer":116},"What specific process changes does the AICPA recommend for filing Forms 3520-A and 3520?",{"text":117,"@type":109},"The AICPA recommends developing a Form 3520 worksheet tailored to foreign trust distributions, changing the due date for Form 3520-A to April 15 with extensions, and adopting a uniform method for filing prior years’ Forms 3520 and 3520-A.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},304764,1790328647,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":79,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":73},34359740700684,"https://ap-avatar.wpscdn.com/avatar/1f400023980c374ae676?_k=1777273430885731487","June 17, 2003  \nMr. Glenn Kirkland  \nInternal Revenue Service, Room 6411 1111 Constitution Avenue, N.W.  \nWashington, D.C. 20224  \nRE: Comments on Form 3520-A and Form 3520  \nDear Mr. Kirkland:  \nThe American Institute of Certified Public Accountants (AICPA) is writing in response to the Service’s April 18, 2003, request for comments on Form 3520-A, “Annual Information Return of Foreign Trust with a U.S. Owner.” Although not specifically requested, we have also commented on Form 3520, “Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts” because it is closely linked to Form 3520-A. The AICPA is the national, professional organization of certified public accountants comprised of more than 350,000 members. Our members advise clients on federal, state, and international tax matters, and prepare income and other tax returns for millions of Americans. They provide services to individuals, notfor-profit organizations, small and medium-sized businesses, as well as America's largest businesses.  \nIn our attached comments, we urge the IRS to: (1) exempt Canadian Registered Retirement Savings Plans (RRSPs) and Registered Education Savings Plans (RESPs) from the Form 3520-A filing requirements, and exempt their U.S. owners from the Form 3520 filing requirements for reporting transfers to RRSPs and RESPs; (2) develop a Form 3520 worksheet tailored to foreign trust distributions as a substitute for using Form 4970;(3) change the due date for Form 3520-A to April 15, with extensions; and (4) adopt a uniform method for filing prior years’ Forms 3520 and 3520-A to facilitate compliance.  \nThank you for the opportunity to comment on these forms. Please feel free to contact meat (202) 414-1705, or [Robert.zarzar@us.pwcglobal.com](Robert.zarzar@us.pwcglobal.com) ; Rick Gimbert, Chair of the Form 3520 Task Force, at (404) 220-1849, or [rgimbert@deloitte.com](rgimbert@deloitte.com) ; or Eileen Sherr, AICPA Technical Manager, at (202) 434-9256, or [esherr@aicpa.org](esherr@aicpa.org), to discuss any of our comments further. Thank you for taking the time to consider this matter.  \nSincerely,  \nRobert A. Zarzar  \nChair, Tax Executive Committee  \ncc: Willard W. Yates, IRS Office of the Associate Chief Counsel (International)  \nAmanda A. Ehrlich, IRS Office of Associate Chief Counsel (International) Barbara Angus, U.S. Department of Treasury International Tax Counsel  \nAICPA COMMENTS ON FORM 3520-A AND FORM 3520  \nA. Canadian RRSPs and RESPs Should Not Be Subject to Filing Forms 3520-A and 3520  \n1. Canadian Registered Retirement Savings Plans  \nCurrently, any Canadian Registered Retirement Savings Plan (RRSP) with a U.S. owner, which is treated as a foreign trust, must file a Form 3520-A. However, no Form 3520-Ais required if the U.S. beneficiary files an election under Rev. Proc. 2002-23, 2002-15 I.R.B. (March 26, 2002), to defer U.S. income tax until the income is distributed.  \nAny U.S. citizen or resident who makes a transfer to an RRSP must also file Form 3520 to report the transfer. However, no Form 3520 is required if, at the time of transfer, the RRSP qualifies for exemption under the U.S. -Canada income tax treaty, and this reliance is disclosed on the U.S. person’s income tax return. (See Notice 97-34, 1997-1 C.B. 422.) .  \nIn Notice 2003-25, 2003-18 I.R.B. (May 2, 2003), Treasury and the IRS acknowledge that many U.S. persons with interests in RRSPs – as well as RRSP custodians – are unfamiliar with the requirements for filing Forms 3520 and 3520-A. Therefore, the Notice delays the imposition of these filing requirements on RRSPs until the 2002 tax year, with an automatic due date extension for 2002 filings to August 15, 2003. The Notice also affirms that RRSPs have no filing obligation for any year in which the plan beneficiary elects under Rev. Proc. 2002-23.  \nIt is unclear whether an RRSP meets the reg. section 301.7701-4 definition of a “trust,” asan arrangement in which trustees take title to ","cbCaikzlOfmQoDG9","https://ap.wps.com/l/cbCaikzlOfmQoDG9","pdf",104454,6,"English","# Comments on Form 3520-A and Form 3520\n## A. Canadian RRSPs and RESPs Should Not Be Subject to Filing Forms 3520-A and 3520\n### 1. Canadian Registered Retirement Savings Plans\n### 2. Canadian Registered Education Savings Plans","[{\"question\":\"Why does the AICPA also comment on Form 3520 when the IRS requested comments on Form 3520-A?\",\"answer\":\"Because Form 3520 is closely linked to Form 3520-A, the AICPA provides comments on both forms to address related filing and reporting obligations.\"},{\"question\":\"What does the AICPA urge regarding Canadian RRSPs and RESPs?\",\"answer\":\"The AICPA urges exempting Canadian RRSPs and RESPs from Form 3520-A filing requirements and exempting their U.S. owners from Form 3520 filing requirements for reporting transfers to RRSPs and RESPs.\"},{\"question\":\"What specific process changes does the AICPA recommend for filing Forms 3520-A and 3520?\",\"answer\":\"The AICPA recommends developing a Form 3520 worksheet tailored to foreign trust distributions, changing the due date for Form 3520-A to April 15 with extensions, and adopting a uniform method for filing prior years’ Forms 3520 and 3520-A.\"}]","AICPA Comments on Form 3520-A and Form 3520 - IRS Filing Recommendations | PDF",1789816984]