01
Penalty
Appeals
Challenge unfair IRS penalties and protect your international tax position.
IRS penalty defense
Hit with a 3520Notice or Penalty?You Have Options.
We focus exclusively on IRS international information return penalties (Form 3520, 3520-A and related).
CP15Received a CP15 notice involving Form 3520? You Have 30 Days to Respond.
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Our core services
Penalty
02
Abatement
Requests
Reduce or remove penalties when you qualify for abatement relief.
03
IRS
Representation
Direct representation with the IRS to resolve your 3520, 3520-A and related issues.
Why this practice
Over 26 years of international tax law experience.
Jason Kovan is a former KPMG Executive Tax Director, U.S. Certified Public Accountant (CPA), and Licensed Private Investigator (PI). His offices are in South Florida and the Middle East, serving clients worldwide.
Former KPMG Executive Tax Director / South Florida + Middle East
Attorney-client privilege applies / Clients worldwide
CP15 NOTICES
IRS CP15 Notices and Form 3520: What You Need to Know.
Receiving an IRS penalty notice can be unsettling, especially when it involves money received from overseas. Understanding why the IRS sent the notice is the first step toward responding.
WHAT IS A CP15 NOTICE?
A CP15 is a letter notifying you that the IRS has charged you a civil penalty. It is not a tax form. The notice identifies the penalty, the amount due, and the reason for the charge. It may also show interest and explain how to challenge the penalty.
HOW DOES IT RELATE TO FORM 3520?
Form 3520 is used to report certain foreign trust transactions, ownership of certain foreign trusts, and some large gifts or inheritances received from foreign persons. A CP15 notice may concern a penalty for failing to meet these reporting requirements. A penalty can apply when a required Form 3520 is filed late, left incomplete, or contains incorrect information. The amount depends on the reporting requirement involved.
HOW MUCH COULD THE PENALTY BE?
For foreign gifts and inheritances that must be reported, the penalty can reach 5% of the unreported amount for each month the reporting failure continues, up to a maximum of 25%. For example, an unreported $200,000 gift could result in a $50,000 penalty at the maximum rate. Different rules apply to foreign trusts. For certain unreported transfers to, or distributions from, a foreign trust, the initial penalty is generally the greater of $10,000 or 35% of the reportable amount. Other trust reporting failures have different calculations.
5% per month, up to 25% maximum
the greater of $10,000 or 35% of the reportable amount
WHAT SHOULD YOU DO IF YOU RECEIVE A NOTICE?
Read the notice carefully and check the response deadline immediately. CP15 notices commonly provide 30 days from the notice date to submit a written protest. Follow the specific instructions on your letter, including where to send your response. The IRS advises taxpayers who disagree with a notice to respond by the stated deadline and include supporting documents. Gather your filing records, proof of mailing, and documents relating to the gift, inheritance, or trust transaction. These can help establish whether the penalty is incorrect or whether you have grounds to request relief.
CAN THE PENALTY BE REMOVED?
The IRS allows relief when you can demonstrate that the reporting failure resulted from reasonable cause rather than willful neglect. In plain English, you need to explain the circumstances that prevented you from meeting the requirement and provide evidence supporting that explanation. Relief depends on the facts; submitting an explanation does not guarantee approval.
Received a CP15 notice involving Form 3520?
Start by confirming the notice date, the tax year involved, and whether the penalty concerns a foreign gift, inheritance, or foreign trust. A tax professional experienced in international reporting penalties can review the assessment and help prepare an appropriate response.
Quick check
- Confirm the notice date
- Confirm the tax year involved
- Identify whether it concerns a foreign gift, inheritance, or foreign trust
Who we help
Built for cross-border complexity.
Individuals
U.S. expats, U.S. citizens, green card holders, dual nationals, high-net-worth individuals and trust beneficiaries with foreign accounts, overseas assets, foreign trusts or gifts and inheritances.
Businesses & entities
International businesses, foreign corporations, partnerships, and foreign trust owners and trustees facing cross-border reporting obligations, late filings or non-filing penalties.
Confidential by design
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Tell us what arrived from the IRS. We will help you understand the path forward and what a focused defense can involve.
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