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.
Learning Objectives (NASBA)
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.
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*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.
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