Form 3520

Department of the Treasury

Internal Revenue Service

Annual Return To Report Transactions With

Foreign Trusts and Receipt of Certain Foreign Gifts

OMB No. 1545-0159

For calendar year 1999, or tax year beginning , 19 , ending , .

Check appropriate box(es): See Instructions. Initial return Final return Amended return

All information must be in English. Show all amounts in U.S. dollars. File a separate Form 3520 for each foreign trust.

1a b

2a c

5a c

6a

Name of U.S. person(s) filing return Identification number

Number, street, and room or suite no. (If a P.O. box, see instructions.)

City or town

Name of foreign trust (if applicable) Identification number (if any)

(a) You are a U.S. transferor who, directly or indirectly, transferred money or other property during the current tax year to a foreign trust, or 

(b) You held an outstanding obligation of a related foreign trust (or a person related to the trust) issued during the current tax year, that you

treated as a “qualified obligation” (defined on page 3 of the instructions) during the current tax year. See the instructions for Part I.

You are a U.S. owner of all or any portion of a foreign trust at any time during the tax year. See the instructions for Part II.

(a) You are a U.S. person who, during the current tax year, received a distribution from a foreign trust, or (b) A related foreign trust held an

outstanding obligation issued by you (or a person related to you) during the current tax year that you treated as a “qualified obligation”

(defined on page 3 of the instructions) during the current tax year. See the instructions for Part III.

You are a U.S. person who, during the current tax year, received certain gifts or bequests from a foreign person. See the instructions for

Part IV.

Service Center where U.S. person filing this return files its income tax return 

Part I Transfers by U.S. Persons to a Foreign Trust During the Current Tax Year (See instructions on page 5.)

Name of trust creator (if different

from line 1a)

Identification number (if any)

Country code of country where trust was created Country code of country whose law governs the trust Date trust was created

Under penalties of perjury, I declare that I have examined this return, including any accompanying reports, schedules, or statements, and to the best of my

knowledge and belief, it is true, correct, and complete.

Signature Title Date

Preparer’s signature Preparer’s SSN or PTIN

Cat. No. 19594V Form 3520 (1999)

d Spouse’s identification number (see instr.)

Date

c

e f State or province g ZIP or postal code h Country

b Number, street, and room or suite no.

d City or town e State or province f ZIP or postal code g Country

b Address

4a Name of U.S. decedent (see instr.) b Address c TIN of decedent

b c

d Date of death e EIN of estate

Check box that applies to U.S. person filing return: Individual Partnership Corporation Trust Executor

File in duplicate. Instructions are separate.

For purposes of section 6048(b), did the foreign trust appoint a U.S. agent (defined on page 4 of the instructions)

who can provide the IRS with all relevant trust information? Yes No

If “Yes,” complete lines 3a through 3g.

3

3a Name of U.S. agent b Identification number (if any) c Number, street, and room or suite no.

d City or town e State or province f ZIP or postal code g Country

Check all applicable boxes:

7a Will any other person be treated as the owner of the transferred assets after the transfer? Yes No

Name of other foreign

trust owners, if any

(a)

Address

(b)

Country of residence

(c)

Identification number,

if any

(d)

Relevant

code section

(e)

b

For Paperwork Reduction Act Notice, see page 10 of the instructions.

1999

A

B

Attachment

Sequence No. 120
Form 3520 (1999) Page 2

Part I ( Continued)

Yes No

11a

12

13

Schedule A—Obligations of a Related Trust (See instructions on page 5.)

During the current tax year, did you transfer property (including cash) to a related foreign trust in exchange for an

obligation of the trust or a person related to the trust? See instructions

If “Yes,” complete Schedule A, as applicable. If “No,” go to Schedule B.

Date of transfer giving rise to obligation

(a)

Maximum term

(b)

Yield to maturity

(c)

FMV of obligation

(d)

Note: Generally, you must answer “Yes,” if you checked “Yes” to question 11b.

Schedule B—Gratuitous Transfers (See instructions on page 6.)

During the current tax year, did you make any transfers (directly or indirectly) to the trust and receive less than

FMV, or no consideration at all, for the property transferred?

If “Yes,” complete columns (a) through (i) below and the rest of Schedule B, as applicable.

If “No,” do not complete the rest of Schedule B and go to Schedule C.

Date of

transfer

(a)

Description

of property

transferred

(b)

FMV of property

transferred

(c)

U.S. adj. basis

of property

transferred

(d)

Gain recognized

at time of

transfer

(e)

Excess, if any,

of column (c)

over the sum of

columns (d)

and (e)

(f)

Description

of property

received,

if any

(g)

FMV of property

received

(h)

Excess of

column (c) over

column (h)

(i)

Totals 

Yes No

$

Yes No

With respect to each obligation you treated as a “qualified obligation” on line 11b: Do you agree to extend the

period of assessment of any income or transfer tax attributable to the transfer and any consequential income tax

changes for each year that the obligation is outstanding, to a date 3 years after the maturity date of the obligation?

b Was the obligation you received a qualified obligation? Yes No

If “Yes,” complete Schedule A with respect to that obligation. If “No,” go to Schedule B.

You are required to attach a copy of each sale or loan document entered into in connection with a transfer reported on line 13. If these

documents have been attached to a Form 3520 filed within the previous 3 years, attach only relevant updates.

b

Have you attached a copy of:

Sale document?

Loan document?

Yes No

Attached

Previously

Year

Attached

a

c Subsequent variances to original sale or loan documents?

14

8 Was the transfer a completed gift or bequest? If “Yes,” see instructions Yes No

9a

b

Yes No

Yes No

Can any part of the income or corpus of the trust benefit, now or in the future, any U.S. beneficiary?

If “No,” could the trust be revised or amended to benefit a U.S. beneficiary?

10 Will you continue to be treated as the owner of the transferred asset(s) after the transfer? Yes No

$

Note: The FMV of an obligation (column (d)) is -0- unless it is a qualified obligation.

Form 3520 (1999)
Form 3520 (1999) Page 3

15

Name of beneficiary

(a)

Address of beneficiary

(b)

Identification number, if any

(d)

You are required to attach a copy of all trust documents as indicated below. If these documents have been attached to a Form 3520-A

filed within the previous 3 years, attach only relevant updates.

U.S. beneficiary?

(c)

Yes No

b

Have you attached a copy of:

The trust instrument?

Memoranda or letters of wishes?

Summary of all written and oral agreements and understandings relating to the trust?

Subsequent variances to original trust documents?

Yes No

Attached

Previously

Year

Attached

a

c

d

f Other trust documents?

18

Name of trustee

(a)

Address of trustee

(b)

Identification number, if any

(c)

16

Name of other persons

with trust powers

(a)

Address of other persons with trust powers

(b)

Identification number, if any

(d)

Description of

powers

(c)

17

Note: Complete lines 15 through 18 only if you answered “No” to line 3.

Part I ( Continued)

e Trust financial statements?

Form 3520 (1999)
Form 3520 (1999) Page 4

Part III

Part II U.S. Owner of a Foreign Trust (See instructions on page 6.)

Name of other foreign

trust owners, if any

(a)

Address

(b)

Country of residence

(c)

Identification number,

if any

(d)

Relevant

code section

(e)

Country code of country where foreign trust

was created

(a)

Country code of country whose law governs the foreign trust

(b)

Date foreign trust was created

(c)

20

21

Did the foreign trust file Form 3520-A for the current year?

If “Yes,” attach the Foreign Grantor Trust Owner Statement you received from the foreign trust. If “No,” to the

best of your ability, complete and attach a substitute Form 3520-A for the foreign trust. See page 4 of instructions

for information on penalties.

Enter the gross value of the portion of the foreign trust that you are treated as owning 

Yes No

Distributions to a U.S. Person From a Foreign Trust During the Current Tax Year (See instructions on page 7.)

22

Cash amounts or FMV of property received, directly or indirectly, during the current tax year, from the foreign trust (exclude loans included on line 25).

Date of distribution

(a)

Description of property received

(b)

FMV of property received

(determined on date of

distribution)

(c)

23

24

Totals  $

$

Schedule C—Qualified Obligations Outstanding in the Current Tax Year (See instructions on page 6.)

19 Did you, at any time during the tax year, hold an outstanding obligation of a related foreign trust (or a person

related to the trust) that you treated as a “qualified obligation” in the current tax year?

If “Yes,” complete columns (a) through (e) below.

Date of original

obligation

(a)

Tax year qualified

obligation first reported

(b)

Amount of principal

payments made during

the tax year

(c)

Amount of interest

payments made during

the tax year

(d)

Does the obligation

still meet the

criteria for a

qualified obligation? (e)

Yes No

Yes No

Description of

property transferred,

if any

(d)

FMV of property

transferred

(e)

Excess of column (c)

over column (e)

(f)

Part I

Form 3520 (1999)
Form 3520 (1999) Page 5

Part III ( Continued)

Schedule A—Default Calculation of Trust Distributions (See instructions on page 8.)

36

Enter amount from line 27

37

Enter total distributions received from the foreign trust during the 3 preceding tax years (or the number of years

the trust has been a nongrantor trust, if fewer than 3)

39

Average distribution. Divide line 34 by 3 (or the number of years the trust has been a nongrantor trust, if fewer

than 3) and enter the result

40

Amount treated as accumulation distribution. Subtract line 36 from line 31. If -0- or less, enter -0- and do not

complete the rest of Part III

42

Number of years the trust has been a nongrantor trust (see instructions). 

43

Compute applicable number of years of trust. Divide line 32 by 2 and enter here 

Schedule B—Actual Calculation of Trust Distributions (See instructions on page 8.)

44

Enter amount from line 27

45

Amount treated as ordinary income in the current tax year

46

Amount treated as accumulation distribution. If -0- or less, enter -0- and do not complete the rest of Part III

47

Amount treated as capital gains in the current tax year

Amount treated as distribution from trust corpus

Enter any other distributed amount received from the foreign trust not included on lines 40, 41, 42, and 43 (attach explanation)

Compute applicable number of years of trust. Divide line 46 by line 45 and enter here 

33

Did you receive a Foreign Grantor Trust Beneficiary Statement from the foreign trust with respect to a distribution?

If “Yes,” attach the statement and do not complete the remainder of Part III with respect to that distribution.

34

Did you receive a Foreign Nongrantor Trust Beneficiary Statement from the foreign trust with respect to a distribution?

Yes No

Yes No

35

38

Multiply line 33 by 1.25

28

Amount treated as ordinary income earned in the current year. Enter the smaller of line 31 or line 35

41

Amount of foreign trust’s aggregate undistributed net income

Amount of foreign trust’s weighted undistributed net income

Date of original loan

transaction

(a)

Amount of actual principal

payments made during

the tax year

(c)

Amount of actual

interest payments

made during

the tax year

(d)

Does the loan still meet the

criteria of a qualified

obligation?

(e)

Yes No

32

31

30

29

Tax year

qualified obligation

first reported

(b)

Did the trust, at any time during the tax year, hold an outstanding obligation of yours (or a person related to you)

that you treated as a “qualified obligation” in the current tax year?

If “Yes,” complete columns (a) through (e) below with respect to each obligation.

Yes No

FMV of loans proceeds

(a)

Date of original

loan transaction

(b)

Maximum term of

repayment of

obligation

(c)

Interest rate

of obligation

(d)

Is the obligation a

“qualified obligation”?

(e)

Yes No 

FMV of obligation

(f)

Amount treated as distribution

from the trust (subtract

column (f) from column (a))

(g)

Note: Generally, you must answer “Yes” if you checked “Yes” in column (e) of line 25. 

With respect to each obligation you treated as a “qualified obligation” on line 25: Do you agree to extend the

period of assessment of any income or transfer tax attributable to the transaction, and any consequential income

tax changes for each year that the obligation is outstanding, to a date 3 years after the maturity date of the

obligation?

Total distributions received during the current tax year. Add line 24, column (f), and line 25, column (g) 

$

26

Yes No

27 $

During the current tax year, did you (or a person related to you) receive a loan from a related foreign trust (including

an extension of credit upon the purchase of property from the trust)? Yes No

25

If “Yes,” complete columns (a) through (g) below with respect to such loans.

Note: The FMV of an obligation (column (f)) is -0- unless it is a “qualified obligation.”

Total 

If “Yes,” attach the statement and complete either Schedule A or Schedule B below (see instructions). If “No,”

complete Schedule A with respect to that distribution.

If “No,” complete Schedule A with respect to that distribution.

Form 3520 (1999)
Form 3520 (1999) Page 6

Description of property received

(b)

Date of gift

or bequest

(a)

FMV of property received

(c)

Total  $

U.S. Recipients of Gifts or Bequests Received During the Current Tax Year From Foreign Persons (See instructions

on page 9.)

Part IV

54

(e)

Yes No

During the current tax year, did you receive more than $100,000 during the tax year that you treated as gifts or

bequests from a nonresident alien or a foreign estate? See instructions regarding related donors

If “Yes,” complete columns (a) through (c) with respect to each such gift or bequest in excess of $5,000. If more

space is needed, attach schedule.

During the current tax year, did you receive more than $10,735 that you treated as gifts from a foreign corporation

or a foreign partnership? See instructions regarding related donors

If “Yes,” complete columns (a) through (g) with respect to each such gift. If more space is needed, attach schedule.

Date of gift

(a)

Name of donor

(b)

Address of donor

(c)

Identification number,

if any

(d)

Check the box that applies to the foreign donor

Corporation Partnership

Description of property received

(f)

FMV of property received

(g)

Do you have any reason to believe that the foreign donor, in making any gift or bequest described in lines 54 and

55, was acting as a nominee or intermediary for any other person? If “Yes,” see instructions.

Yes No

Yes No

55

56

48

49

50

51

Schedule C—Calculation of Interest Charge (See instructions on page 9.)

Enter accumulation distribution from line 37 or 41, as applicable

Enter tax on total accumulation distribution from line 28 of Form 4970

Combined interest rate imposed on the total accumulation distribution. See Table B on page 9 of instructions

Interest charge. Multiply the amount on line 49 by the combined interest rate on line 51

Tax attributable to accumulated distributions. Add lines 49 and 52. Enter here and as “additional tax” on your

income tax return

52

53

Part III ( Continued)

Enter applicable number of years of foreign trust from line 38 or 47, as applicable (round to nearest half-year). 

Form 3520 (1999)