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A distribution also includes constructive transfers from a trust. If you are a grantor or beneficiary of a foreign trust and you (or a U. person related to you) directly or indirectly received a loan of cash or marketable securities from a foreign trust, or you (or a U. person related to you) used any property owned by a foreign trust without paying FMV within a reasonable amount of time, the amount of such loan or the FMV of the use of trust property will be treated as a distribution for reporting purposes. 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. However, you may not treat the foreign trust as having a U. agent unless you enter the name, address, and taxpayer identification number (TIN) of the U. agent on lines 3a through 3g on page 1 of the form. If the agent's responsibility as an agent of the trust is terminated for any reason (for example, agent's resignation, agent's liquidation, or agent's death), see section IV(B) of Notice 97-34. If applicable, enter the reference ID number (defined below) you have assigned to the foreign trust.For example, if charges you make on a credit card 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 you by the foreign trust. For this purpose, a loan by an unrelated third party that is guaranteed by a foreign trust is generally treated as a loan from the trust. 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. A gratuitous transfer to a foreign trust is any transfer to the trust other than (a) a transfer for FMV; or (b) a distribution to the trust with respect to an interest held by the trust (i) in an entity other than a trust (for example, a corporation or a partnership), or (ii) in an investment trust described in Regulations section 301.7701-4(c), a liquidating trust described in Regulations section 301.7701-4(d), or an environmental remediation trust described in Regulations section 301.7701-4(e). person will not be treated as making a transfer for FMV merely because the transferor is deemed to recognize gain on the transaction. beneficiary, or a domestic corporation controlled by the grantor or beneficiary may act as a U. For Form 3520 purposes, a "reference ID number" with respect to the foreign trust is a number established with respect to the foreign trust by or on behalf of the U. person that is engaged in a transaction with such foreign trust with respect to which Form 3520 reporting is required.( means an entity, if the entity’s gross income attributable to the holding of financial assets for the account of others and related financial services equals or exceeds 20% of the entity’s gross income during the shorter of means an investment entity that is regulated as a collective investment vehicle, provided that all of the interests in the collective investment vehicle are held by or through individuals or entities (other than a passive NFE with a controlling person who is a reportable person) that are not reportable persons.( means the government of a jurisdiction, any political subdivision of a jurisdiction (which, for greater certainty, includes a state, province, county or municipality), a public body performing a function of government in a jurisdiction or any agency or instrumentality of a jurisdiction wholly owned by one or more of the foregoing, unless it is not an integral part or a controlled entity of a jurisdiction (or a political subdivision of a jurisdiction) and for these purposes means a contract (other than an annuity contract) under which the issuer agrees to pay an amount upon the occurrence of a specified contingency involving mortality, morbidity, accident, liability or property risk. owner's tax return must be consistent with the Form 3520-A, Annual Information Return of Foreign Trust With a U. Owner, filed by the foreign trust unless you report the inconsistency to the IRS. For purposes of the general rule described earlier, if any U. 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. person, such agreement or understanding will be treated as a term of the trust. If this is the initial return you are filing concerning the foreign trust identified and you have filed an extension with respect to your income tax return, check the "Initial return (extension filed)" box.A distribution includes the receipt of trust corpus and the receipt of a gift or bequest described in section 663(a). 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. The agency relationship must be established by the time the U. person files Form 3520 for the relevant tax year and must continue as long as the statute of limitations remains open for the relevant tax year. person to act as an agent for purposes of section 6048(b)(2) or for purposes of section 6048(c)(2)(A), the trust and the agent must enter into a binding agreement substantially in the format reflected under A U. However, filers are permitted to enter both an EIN on line 2b(1) and a reference ID number on line 2b(2).
If a person enters into an arrangement or engages in a practice, the primary purpose of which can reasonably be considered to be to avoid an obligation under this Part, the person is subject to the obligation as if the person had not entered into the arrangement or engaged in the practice.
See An obligation includes any bond, note, debenture, certificate, bill receivable, account receivable, note receivable, open account, or other evidence of indebtedness, and, to the extent not previously described, any annuity contract. If for any reason a reference ID number is not being used (for example, the foreign trust is terminated and no longer exists), the reference ID number used for that foreign trust cannot be used again for another foreign trust for purposes of Form 3520 reporting.
A person is related to a foreign trust if such person, without regard to the transfer at issue, is a grantor of the trust, a beneficiary of the trust, or is related to any grantor or beneficiary of the trust. For example, in the case of a trust that has received assets from another trust, a Form 3520 filer must use a reference ID number for the receiving trust which correlates the previous reference ID number for the distributing trust with the new reference ID number assigned to the receiving foreign trust.
As indicated above, the length of a given reference ID number is limited to 50 characters and each number must be alphanumeric and no special characters are permitted. You must also check the applicable box on line 4f to indicate which of the following applies: the U. decedent made a transfer to a foreign trust by reason of death, the U. decedent was treated as the owner of a portion of a foreign trust immediately prior to death, or the estate of the U. Accordingly, the regulations under sections 679 and 684 should be referred to for additional clarification for transfers that are required to be reported in Part I of Form 3520. If you are the trust creator, enter "Same as line 1a" on line 5a.
If you are not the trust creator, enter the name of the person who created or originally settled the foreign trust., earlier, for specific information regarding the entering of addresses and identification numbers on Form 3520.
You must correlate the reference ID numbers as follows: New reference ID number, Old reference ID number.