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Do not enter a PTIN on the authorization form.

Line 2. If the trust did not appoint a U.S. agent, attach the

following documents to Form 3520-A:

A summary of the terms of the trust that includes a

CAUTION

summary of any oral agreements or understandings you

Line 5. Attach a statement that provides the following

have with the trustee, whether or not legally enforceable.

information concerning the transfer:

A copy of all trust documents (and any revisions),

1. Name, U.S. taxpayer identification number (if any),

including the trust instrument, any memoranda of wishes

and country of organization or residence of the person to

prepared by the trustees summarizing the settlor's wishes,

whom the property was transferred.

any letter of wishes prepared by the settlor summarizing

2. A general description of the transfer, and any

his or her wishes, and any similar documents.

broader transaction of which it forms a part, including a

Lines 3a through 3g. If a foreign trust with a U.S. owner

chronology of the transfers involved and an identification

does not have a U.S. agent, the IRS may determine the

of the other parties to the transaction to the extent known.

amounts required to be taken into account with respect to

3. A description of the property transferred, including

the foreign trust by the U.S. owner. See section 6048(b)

the estimated FMV and the adjusted basis of the property.

(2). In order to avoid this, a U.S. owner of a foreign trust

4. A description of the consideration received by the

should ensure that the foreign trust appoints a U.S.

trust, including its estimated FMV, and for stock or

person to act as the foreign trust's limited agent for

securities, the class or type, amount, and characteristics

purposes of applying sections 7602, 7603, and 7604 with

of the interest received. If no consideration was received

respect to a request by the IRS to examine records or

by the trust, indicate whether the trust or a U.S. owner

produce testimony, or a summons by the IRS for such

exercises any powers over the entity to which the property

records or testimony. Any U.S. citizen, resident alien, or

was transferred (including a description of such powers),

domestic corporation (including a U.S. grantor or U.S.

and identify the name, U.S. taxpayer identification number

beneficiary of a foreign trust) may act as the U.S. agent of

(if any), and country of organization or residence of all

the trust.

beneficial owners of such entity.

In order to authorize a U.S. person to act as an agent

5. To the extent known, a description of any

under section 6048(b), the trust and the agent must enter

subsequent transfer of the property, including the name,

into a binding agreement substantially in the format that

U.S. taxpayer identification number (if any), and country of

follows. Attach a copy of the authorization to Form

organization or residence of the person to whom the

3520-A.

property was subsequently transferred.

AUTHORIZATION OF AGENT

The statement must also contain a description of the

[ Name of foreign trust ] hereby expressly authorizes [ name of

trust ownership structure setting forth the name, U.S.

U.S. agent ] to act as its agent solely for purposes of sections

taxpayer identification number (if any), and country of

7602, 7603, and 7604 of the Internal Revenue Code with respect to

organization of all entities in which the trust has an

any request to examine records or produce testimony related to the

proper treatment of amounts required to be taken into account

ownership interest, including an ownership chart showing

under the rules of section 6048(b)(1)(A) or to any summons for such

the trust's position in the chain of ownership and the

records or testimony. I certify that I have the authority to execute

percentages of ownership.

this authorization of agent to act on behalf of [ name of foreign

trust ].

Note. The term “person” includes an individual or an

entity, whether U.S. or foreign. See the definition of U.S.

Signature of trustee

(title)

(date)

person earlier. A foreign person is an individual or entity

(or other authorized person)

that is not a U.S. person.

Part II—Foreign Trust Income

Your Name (type or print)

Statement

Identification Number (if any)

Include all income from U.S. and non-U.S. sources. This

financial statement must reasonably reflect the trust's

Address

income under U.S. income tax principles.

[ Name of agent ] accepts this appointment to act as agent

for [ name of foreign trust ] for the above purpose. I certify that I

Income

have the authority to execute this authorization of agent to act on

behalf of [ name of foreign trust ] and agree to accept service of

Line 1. Interest. Report all taxable interest income that

process for the above purposes.

was received during the tax year. Examples of taxable

interest include, but are not limited to, interest from:

Accounts (including certificates of deposit and money

Signature of agent

(title)

(date)

market accounts) with banks, credit unions, and thrift

institutions.

Your Name (type or print)

Notes, loans, and mortgages.

U.S. Treasury bills, notes, and bonds.

Identification Number (if any)

U.S. savings bonds.

Original issue discount.

Address

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Instructions For Form 3520-A - Annual Information Return Of Foreign Trust With A U.s. Owner - 2015 Page 5

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