
Form 3520-A: The March 15 Deadline, Substitute Filings, and the 5% Section 6677 Penalty
Form 3520-A is the annual information return for a foreign trust with a U.S. owner, due March 15. If the foreign trustee does not file, Section 6677 imposes an initial 5% penalty on trust assets plus $10,000 per 30-day continuation period — payable by the U.S. owner. Covers who files, the substitute filing path, the reasonable-cause defense, and how to clean up multi-year non-compliance.










