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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.

IOLTA and Client Trust Accounting: Three-Way Reconciliation, Earned vs. Unearned Fees, and the Mistakes That End Careers

How law firms run IOLTA accounts under ABA Model Rule 1.15 — separating earned from unearned fees, matching the bank statement to the master ledger and per-client sub-ledgers in a three-way reconciliation, and avoiding the four commingling mistakes (firm money in trust, firm expenses from trust, earned fees left in trust, one client's funds covering another's disbursement) that drive most bar discipline cases.

ESBT vs QSST: How Trusts Can Hold S-Corporation Stock Without Killing the S Election

A trust holding S-corporation stock must qualify as a QSST or ESBT under Section 1361 or the S election terminates retroactively. A QSST taxes pass-through income at the single beneficiary's personal rate; an ESBT permits multiple beneficiaries but traps S-portion income at the 37% top trust rate. The election deadline is two months and sixteen days from the triggering event.

First-Party d(4)(A) vs. Third-Party Special Needs Trusts: Protecting SSI, Medicaid, and a Disabled Loved One's Future

A planning guide to first-party (d)(4)(A), third-party, and (d)(4)(C) pooled special needs trusts. Compares the Medicaid payback obligation, the under-65 statutory cutoff, allowable trust disbursements, the 2024 SSA change that removed food from ISM, and how a 2026 ABLE account complements an SNT without replacing it.

Form 1041 Decoded: Why Trusts Hit 37% at $15,200 and How DNI Saves Beneficiaries

Trusts hit the top 37% federal bracket at just $15,200 of taxable income, while a single individual does not until $609,350. This guide walks fiduciaries through Form 1041, distributable net income (DNI), Schedule K-1 allocations, the separate share rule, and the 65-day election used to shift income to beneficiaries at lower rates.