USA Filing form 3520 in October after filing a 1040 extension- Foreign gift reporting

[Ladybugblue]

Hello!

Someone needs to file a 3520 for foreign gift over $100k in 2020. However, he tells me that it may be risky as the IRS has been treating the filing as late and promptly assessing penalties automatically, even if the form was filed within the extension time.

Any comments on this?
Thanks in advance

 

[bkcpa]

I agree to what he's telling you. I've experienced this and my client got hit with a hefty penalty. I've written IRS to dispute penalties, 7 months later no response.

 

[Ladybugblue]

Ok. Thanks.