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Court Upholds Higher IRS Penalty on Late Filing of Forms 3520 and 3520-A

  • picture of Jennie Cherry
    Jennie Cherry
  • picture of George N. Harris, Jr.
    George N. Harris, Jr.

On 28 July 2021, the Court of Appeals for the Second Circuit handed down its decision in Wilson v United States:

“when an individual is both the sole owner and beneficiary of a foreign trust and fails to timely report distributions she received from the trust, the government has the authority under the IRC [Internal Revenue Code] to impose a 35% penalty.” Download.