Inconsistent Treatment of Items

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. If you are treating items on your tax return differently from the way the foreign trust treated them on its return, file Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR). See Form 8082 for more details.