Late Foreign Gift Reporting: Triage, Strategy, and Risk
When a client fails to report a foreign gift, the issue is rarely just about filing a late Form 3520—it is about determining the right course of action without increasing risk. Practitioners must quickly evaluate exposure, understand available options, and decide how to proceed in a way that balances compliance, penalty mitigation, and professional responsibility.
This program focuses on how practitioners should respond when late foreign gift reporting is discovered. Participants will review the filing requirements under IRC §6039F and the associated penalty framework, but the primary emphasis is on real-world decision-making: what questions to ask, how to assess the facts, and how to determine an appropriate strategy.
The program will explore practical approaches to addressing noncompliance, including reasonable cause considerations, late filing strategies, and common pitfalls to avoid. Special attention is given to practitioner risk, including documentation, client communication, and Circular 230 considerations.
This is not a program about preparing Form 3520—it is a program about what to do when it wasn’t filed and you are now responsible for fixing the problem.
Upon completion of this program, participants will be able to:
-Identify foreign gift reporting requirements under IRC §6039F, including thresholds and filing obligations for Form 3520.
-Evaluate potential penalty exposure associated with late or missed foreign gift reporting.-Analyze client fact patterns to determine appropriate next steps when noncompliance is discovered.
-Apply reasonable cause principles and late filing strategies to mitigate penalties.
-Assess practitioner responsibilities, including documentation, client communication, and risk management considerations.
Only available for TPP unlimited CE subscribers.
"Our best deal is always to become a monthly subscriber"
*Self-Study recording not available for NASBA CPE credit.
IRS Program #: 7Q3WU-T-00887-26
CTEC Course #: 6248-CE-00233
Rita Ryan
,
Esq., LLM
Rita Ryan is the Founder of RRITS and a seasoned Tax Attorney with more than 18 years of experience advising clients on cross-border personal/business taxation, international investment structuring, multi-jurisdictional estate planning, and U.S. tax compliance obligations arising from global activities and holdings. She is widely regarded for her ability to navigate complex international tax regimes and translate evolving regulatory requirements into practical, strategic guidance.
In addition to her client-facing work, Rita serves as a trusted advisor to fellow tax professionals, providing specialized support in identifying international reporting obligations, advising on complex filings, and reviewing workpapers and forms to ensure technical accuracy in an increasingly dynamic international compliance environment.
Prior to founding RRITS, Rita served as Chief Financial Officer and Head of Private Client Services at M+, where she focused on integrated tax, business, and wealth preservation planning for high-net-worth business owners and their families. Earlier in her career, she founded and led Wolf & Co.’s International Tax Services Practice, advising both individuals and entities on the tax planning and compliance aspects of international ownership structures. Rita began her legal career in private practice as an Associate Attorney at Vacovec, Mayotte & Singer, LLP, concentrating on international and domestic taxation, estate planning, and tax controversy matters.
Rita is also an Adjunct Professor in the Graduate Tax Program at Boston University School of Law, where she co-founded and co-teaches the course Foreign Information Reporting and Withholding. In addition, she regularly teaches advanced international tax topics for Tax Practice Pros, LumiQ, and the National Association of Enrolled Agents, contributing to the education of practitioners nationwide.
Recommended Webinars
2024 Tax Controversy Seminar Series
Varies
This on-demand webinar series covers criminal tax, IRS collections, international reporting, tax controversies, AI in tax practice, and entertainment industry taxation, equipping professionals with practical strategies for compliance, dispute resolution, and risk management
FBAR Rescue & 8938 Reasons to File
2 IRS CE/2 CTEC/2 NASBA CPE*
Taxpayers with foreign financial assets may be required to file both the Foreign Bank Account Report (FBAR) and Form 8938 (Statement of Specified Foreign Financial Assets)—but understanding when and how to file can be complex. This webinar guides tax professionals through the key differences, filing thresholds, penalties, and reporting obligations for each form. Learn how to determine filing requirements, avoid common compliance pitfalls, and effectively advise clients with international financial interests. Ensure your clients stay compliant and mitigate risks with a clear understanding of these critical reporting requirements. Only available for TPP unlimited CE subscribers.
International Tax Controversies: Challenges & Strategies - 2025
4 Free NY & NJ CLE, CPE and 4 IRS CE/4 NASBA CPE Credits
This in-depth program provides comprehensive coverage of the tax implications for U.S. taxpayers with foreign income and assets. Participants will explore the complexities of reporting foreign income, compliance requirements for foreign asset disclosure, and strategies for minimizing tax liabilities under international tax treaties. The program addresses key areas such as the Foreign Account Tax Compliance Act (FATCA), the Foreign Bank and Financial Accounts (FBAR) reporting, and the taxation of foreign trusts. It also includes a discussion on the tax treatment of foreign earned income and the benefits of the Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credit (FTC). The session features practical examples and case studies to help attendees navigate the intricacies of international taxation effectively and ensure compliance with both U.S. and foreign tax laws.
Protecting Your Office from “Knock and Talks”
2 IRS CE/2 CTEC/2 NASBA CPE*
“Knock & Talks” are unannounced visits by IRS agents designed to catch tax professionals off guard—often during tax season—to verify compliance on everything from due diligence forms to security practices. This webinar walks you through what to expect if the IRS comes knocking, what the agents are looking for, and how to maintain proper documentation and procedures to protect your practice from hefty penalties or sanctions.
Protecting Your Office from “Knock and Talks”Responding to Math Authority Notices
2 IRS CE/2 CTEC/2 NASBA CPE*
"Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Responding to Math Authority NoticesFBAR Rescue & 8938 Reasons to File
2 IRS CE/2 CTEC/2 NASBA CPE*
Taxpayers with foreign financial assets may be required to file both the Foreign Bank Account Report (FBAR) and Form 8938 (Statement of Specified Foreign Financial Assets)—but understanding when and how to file can be complex. This webinar guides tax professionals through the key differences, filing thresholds, penalties, and reporting obligations for each form. Learn how to determine filing requirements, avoid common compliance pitfalls, and effectively advise clients with international financial interests. Ensure your clients stay compliant and mitigate risks with a clear understanding of these critical reporting requirements. Only available for TPP unlimited CE subscribers.
FBAR Rescue & 8938 Reasons to FileTax Practice Rescue: Insider Secrets to Selling Your Firm for Maximum Value
No CE
Don’t fall for broker hyperbole that can cost you thousands when cashing out! Join us for "Tax Practice Rescue", a hard-hitting, no-nonsense webinar where a seasoned buyer shares real lessons from 100+ deals and 10 successful acquisitions. If you're expecting 1.25x sales, all cash at closing, or think buyers are eager to inherit your $100 tax returns, you need to hear this!
Tax Practice Rescue: Insider Secrets to Selling Your Firm for Maximum ValueTax Fallout Webinar Series
Varies
Tax Practice Pro’s Fallout Webinar Series offers on-demand, IRS CE-approved training covering firm valuation and exit strategy, responding to IRS math error notices, handling “Knock and Talks,” and resolving common IRS compliance issues.
Tax Fallout Webinar SeriesOwe No! When the check Won't Cover the Tax Bill
1 IRS CE/1 NASBA CPE*
Your client has a 2024 balance due they didn't expect, and can’t pay in full—what now? Don’t let unpaid balances turn into client walk-outs and undue stress. This live webinar equips tax professionals with the tools and strategies to help clients who can’t pay their full tax bill by April 15. You will leave this webinar with skills and strategies designed to get your happy clients to pay for their return and leave without stress or worry about the balance.
Owe No! When the check Won't Cover the Tax BillScammed but Deductible? Chief Counsel Advice on Theft Losses from Scams
1 IRS CE/1 NASBA CPE*
Is Your Client’s Scam Loss Deductible? Find Out Now! The IRS has spoken! The latest IRS Chief Counsel Advice (CCA 202511015) clarifies when taxpayers can—and cannot—claim theft loss deductions under IRC § 165. Investment scams? Potentially deductible. Romance scams? No deduction allowed. As a tax pro, it's your job to classify losses correctly and maximize recovery options for your clients!
Scammed but Deductible? Chief Counsel Advice on Theft Losses from ScamsThe Role of Expert Witnesses in Tax Preparation and Tax Controversies
3 Free NY & NJ CLE, CPE and IRS CE/NASBA CPE Credits
Tax Professionals that attend are encouraged to accept a pro bono tax controversy case assignment from NYCLA, an ABA-sponsored Tax Court Pro program or a NY or NJ low-income Tax Clinic.
The Role of Expert Witnesses in Tax Preparation and Tax ControversiesMarch Madness: Is this the FINAL BOI deadline?
1 IRS CE/1 NASBA CPE*
FinCEN Says March 21 is the Deadline... But Will It Stick? If you've been following the rollercoaster that is Beneficial Ownership Information (BOI) reporting, you know the rules have changed, delayed, and litigated their way into the compliance nightmares of tax professionals everywhere. But now, FinCEN has spoken: March 21, 2025, is the due date for most filers. With everything that's happened—court challenges, enforcement uncertainty, and plenty of taxpayer confusion—how confident are you that this will be the final deadline? More importantly, are your clients ready to comply?
March Madness: Is this the FINAL BOI deadline?
Hmm...nothing here yet.
