Delinquent International Information Return Submission Procedures

Disclaimer: The information provided below is for general informational purposes only and should not be considered legal or tax advice. Please consult a qualified professional regarding your specific situation.

IRS Delinquent International Information Return Submission Procedures

If you need to file delinquent or amended international information returns but do not need to enter the IRS Voluntary Disclosure Practice (VDP) or the IRS Streamlined Filing Compliance Procedures, the IRS provides an option—provided the following conditions apply:

You failed to file certain required international information returns.
You have reasonable cause for failing to file on time.
You are not currently under an IRS civil examination or criminal investigation; and
You have not been contacted by the IRS regarding these delinquent returns.

How to File Delinquent International Information Returns

If you meet the criteria above, you may file the delinquent information returns along with a Reasonable Cause Statement, which must:

✅ Clearly explain the facts and circumstances that prevented timely filing;
✅ Include a certificate that the relevant entity was not involved in tax evasion.

Important: If a reasonable cause statement is not submitted with each delinquent information return, the IRS may assess penalties under existing procedures.

Filing Instructions

For all delinquent international information returns except Forms 3520 and 3520-A
Attach the delinquent returns to an amended tax return and file them according to the amended return instructions.
For Forms 3520 and 3520-A
File these forms separately, following the official instructions for each form.

In all cases, a reasonable cause statement must be attached to each delinquent return where penalty relief is being requested.

Filing delinquent international information returns with amended returns does not automatically trigger an IRS audit. However, these filings may still be selected for audit under the IRS’s standard selection processes.

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Delinquent International Information Return Submission Procedures

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