The purpose of this reminder is to make sure you meet important IRS deadlines, which are fast approaching. These deadlines apply, for example, to any Integrated Estate Planning Trust (“IEPT”) classified as a foreign trust for U.S. tax purposes. There are certain filing requirements that must be met by both the settlor(s) of a foreign trust as well as by the trustee of the IEPT. Furthermore, any beneficiaries of the IEPT who received any distributions during 2020 should be made aware of their own filing requirements as mentioned below.

Below is a list of the various forms that may need to be filed and their respective annual due dates:

Document Filing Date
IRS Form 3520-A March 15 for most trusts (technically the 15th day of the 3rd month after the trust’s taxable year-end)
IRS Form 3520 April 15
IRS Form 1040NR June 15 (or April 15 if the trust has a U.S. office)
Appointment of U.S. agent Before filing IRS Form 3520-A (before March 15)
FinCEN Form 114 April 15 unless automatically extended to October 15
IRS Form 8938 April 15
Form FSA-153 Within 90 days of a transfer of agricultural property

As stated above, there are also certain filing requirements that need to be observed by certain IEPT beneficiaries who received a distribution during the tax year. The two forms mentioned above that apply to any such beneficiary are Form 3520 and Form 8938, both of which would be due by April 15.

Except for the Appointment of the U.S. agent, there can be substantial penalties for any late filing of the aforementioned forms.