Who Must File

File Form 3520 if any one or more of the following apply.

1. You are the responsible party for reporting a reportable event that occurred during the current tax year, or you are a U.S. person who transferred property (including cash) to a related foreign trust (or a person related to the trust) in exchange for an obligation or you hold a qualified obligation from that trust that is currently outstanding. For definitions, see Responsible Party, Reportable Event , Qualified Obligation , and Person related to a foreign trust , later.

Complete the identifying information on page 1 of the form and the relevant portions of Part I. See the instructions for Part I .

2. You are a U.S. person who, during the current tax year, is treated as the owner of any part of the assets of a foreign trust under the rules of sections 671 through 679.

U.S. person and owner are defined later.

Complete the identifying information on page 1 of the form and Part II. See the instructions for Part II . Note: You are required to complete Part II even if there have been no transactions involving the trust during the tax year. You may also be required to complete a substitute Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner, and attach it to your Form 3520. See Penalties , later.

3. You are a U.S. person (including a U.S. owner) or an executor of the estate of a U.S. person who received, directly or indirectly, a distribution from a foreign trust during the current tax year; or you are a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year you or a U.S. person related to you received (1) a loan of cash or marketable securities (including an extension of credit) directly or indirectly from such foreign trust, or (2) the uncompensated use of trust property; or you are a U.S. person who is a U.S. owner or beneficiary of a foreign trust and in the current tax year such foreign trust holds an outstanding qualified obligation of yours or a U.S. person related to you. For definitions, see U.S. Person, Owner, Distribution , U.S. Beneficiary , and Related Person , later.

Instructions for Form 3520 (Rev. 12-2025) Catalog Number 23068I Oct 7, 2025 Department of the Treasury Internal Revenue Service www.irs.gov

Complete the identifying information on page 1 of the form and Part III. In the case of a U.S. person that is an estate, check “Executor” on line B on page 1. See the instructions for Part III .

4. You are a U.S. person who, during the current tax year, received either:

any other Canadian retirement plan that is within the meaning of section 3 of Rev. Proc. 2014-55. See Rev. Proc. 2014-55, 2014-44 I.R.B. 753, available at IRS.gov/IRB/2014-44_IRB#RP-2014-55 .

a. More than $100,000 from a nonresident alien individual or a foreign estate (including foreign persons related to that nonresident alien individual or foreign estate) that you treated as gifts or bequests; or

b. More than the section 6039F threshold amount from foreign corporations or foreign partnerships (including foreign persons related to such foreign corporations or foreign partnerships) that you treated as gifts. The threshold amount is available at IRS.gov/ InflationAdjustment . Select the applicable tax year news release, then click on the Rev. Proc. link and search for section 6039F to see the threshold amount under Notice of Large Gifts Received from Foreign Persons.

• Certain eligible individuals’ transfers to, ownership of, and distributions from certain tax-favored foreign retirement trusts and certain tax-favored foreign nonretirement savings trusts, as described in section 5 of Rev. Proc. 2020-17. For more information about whether you are an eligible individual and whether your foreign trust qualifies for an exemption from foreign trust information reporting, see Rev. Proc. 2020-17, 2020-12 I.R.B. 539, available at IRS.gov/IRB/2020-12_IRB#REV- PROC-2020-17 .

Complete the identifying information on page 1 of the form and Part IV. See the instructions for Part IV .

Exceptions To Filing Form 3520 does not have to be filed to report the following transactions.

• Transfers to funded nonqualified deferred compensation arrangements described in section 402(b); stock bonuses, pensions, or profit-sharing trusts that would qualify for exemption under section 501(a) except for the fact that it is a trust created or organized outside the United States described in section 404(a)(4); and amounts paid or accrued by an employer under a qualified foreign plan described in section 404A.

• Most fair market value (FMV) transfers by a U.S. person to a foreign trust. However, some FMV transfers must nevertheless be reported on Form 3520 (for example, transfers in exchange for obligations that are treated as qualified obligations, transfers of appreciated property to a foreign trust for which the U.S. transferor does not immediately recognize all of the gain on the property transferred, and transfers involving a U.S. transferor that is related to the foreign trust). See section III of Notice 97-34, 1997-25 I.R.B. 22, available at IRS.gov/pub/irs-irbs/ irb97-25.pdf .

• Certain eligible individuals’ transactions with, and ownership of, certain tax-favored foreign trusts that are established and operated exclusively or almost exclusively to provide pension or retirement benefits, or to provide medical, disability, or educational benefits, as described in proposed regulations under section 6048. You may rely on these proposed regulations for any tax year ending after May 8, 2024, and beginning on or before the date that final regulations are published in the Federal Register, provided you and all related persons (within the meaning of sections 267(b) and 707(b)(1)) apply the proposed regulations in their entirety and in a consistent manner for all tax years beginning with the first tax year of reliance until the applicability date of the final regulations. For more information on whether you are an eligible individual and whether your foreign trust qualifies for an exemption from foreign trust information reporting, see Proposed Regulations section 1.6048-5 as published in the Federal Register at govinfo.gov/content/pkg/FR-2024-05-08/pdf/ 2024-09434.pdf .

The exemptions from foreign trust information reporting described in Rev. Proc. 2014-55, Rev. Proc. 2020-17, and the proposed regulations under section 6048 do not affect any other reporting obligations.