Form 3520. "IRS Tax Penalty Relief and Abatement.

Jason Kovan, International Tax Attorney

Over 26 years of international tax law expertise.

We focus on appealing 3520 fines and filing for tax penalty abatements for individuals and companies who have been assessed by the IRS for failure to file Form 3520 or Form 3520-A.

Jason Kovan's "" Is Focused Exclusively on Appealing Tax Penalties Arising From Late or Non-filing of IRS Form 3520 and Form 3520-A.

If you have received a 3520 tax penalty, wouldn't you want the right person in your corner handling the complexities of filing for abatement and correspondence with the IRS? 

You are not protected by client-confidentiality & attorney-client privilege should you decide to Speak directly with the IRS.

3520 Tax Penalties are Assessed by the IRS When Form 3520 Has Not Been Filed or When Submitted After the Filing Deadline.

Form 3520 penalties related to foreign trusts can be complicated. 

The appeal process with the IRS needs to be properly managed especially since the IRS has become much more aggressive in tracking down and penalizing U.S. taxpayers who fail to report foreign financial assets required by the U.S. tax code.

Why Choose an International Tax Attorney?

Jason Kovan, JD has extensive international tax experience. Mr. Kovan has worked for some of the world’s largest global tax firms, overseas in Europe and the Middle-East. 

As former Executive Tax Director with KPMG, Jason provided tax advise covering a wide-range of legal and accounting issues to high net-worth individuals, professionals, business owners, and corporations who require personal attention and international tax oversight.

about Jason Kovan

Over 26 years of international tax law expertise to safeguard you, your family and your business.

U.S. International tax attorney, Jason Kovan has expertise in appealing 3520 Form tax penalties accessed by the IRS.

Jason has been stationed in the United States, and international cities including Zurich, London and the Middle East. Jason's firm represents clients in the U.S., Canada, Europe, the Middle-East, Central and South America, India, Hong Kong and Singapore and includes U.S. expatriates (U.S. citizens), U.S. taxpayers, U.S. residents, dual-nationals and Green Card holders, individuals or businesses with foreign accounts (including stocks and cash-like investments), and high net-worth clients.  

Mr. Kovan's offices are located South Florida and in the Middle East. Jason and his team of tax experts have prepared and reviewed tens of thousands of individual, corporate, and partnership tax returns. Jason Kovan is also a U.S. Certified Public Accountant (CPA) and licensed Private Investigator (PI).

Jason has appeared on syndicated radio, and as a guest speaker at international symposiums.

OUR approach

Discover how we make a difference

Specialized Knowledge & Expert Representation

Our tax law firm focuses on Forms 3520 and 3520A, meaning that we have a deep understanding of the specific requirements and nuances of these forms, and can provide expert guidance to help you navigate the complex filing process.

Our tax law firm has specialized knowledge and experience in representing clients before the IRS regarding penalties related to Forms 3520 and 3520A. Our firm is well-versed in the laws and regulations and can provide expert representation when you need to navigate the appeals process.

Increased Accuracy

By focusing solely on 3520 forms, we are able to stay up-to-date on any changes or updates and laws, which can help ensure that your filings are accurate and in compliance with the latest regulations.


Because we are very familiar with the 3520 & 3520A forms, we work more efficiently and quickly, which can save you valuable time and effort.

Reduced Risk & Mitigation of Penalties

We identify and address any potential issues or red flags before they become a problem, reducing the risk of penalties or fines from the IRS. Our attorneys negotiate and mitigate penalties assessed by the IRS, potentially reducing the amount of the penalty or by abatement.

Identification of Errors

We review your original filing and identify any errors or omissions that may have led to the penalty, and work to address them to ensure that the same mistakes do not happen in the future.

Handling of Appeals

Our attorneys will represent you in appeals or disputes related to the penalty and navigate the 3520 and 3520A appeals process on your behalf.

Understanding of IRS Processes  & Your Peace of Mind

We have a clear and deep understanding of the IRS’s processes and procedures and will navigate the bureaucracy to ensure that your case is handled efficiently and effectively.

Form 3520 and Form 3520-A

Form 3520 is used to report certain transactions involving foreign trusts, including the creation of a foreign trust, the transfer of property to a foreign trust, and the receipt of certain distributions from a foreign trust. Form 3520 is filled by the U.S. taxpayer.

Form 3520-A is submitted to the IRS by the trustee when there are beneficiaries or owners of the trust who need to file U.S. tax returns.

Form 3520 & 3520-A Tax Penalties

3520 and 3520-A tax penalties are accessed by the IRS when these forms have not been filed or when submitted after the filing deadline.

3520 Penalty Appeal

Attorney, Jason Kovan has over 26 years of international tax experience. Over 80% of Jason's clients are international businesses and US expats living abroad.

Attorney, Jason Kovan has extensive knowledge of U.S. tax law applicable to foreign trusts and disclosures, the proper tax filing regulations applicable to Form 3520 and how to appeal tax penalties imposed by the IRS for non-compliance.

Filing A Form 3520 APPEAL

3520 Appeal

What is involved in filing a 3520 tax penalty appeal?

Filing a 3520 tax penalty appeal can be a complex process, and it's recommended that you work with an international tax attorney who has expertise appeal procedures.

The specific steps involved in filing a 3520 tax penalty appeal will depend on your individual circumstances, but generally speaking, the process may involve the following:

1. Review the facts and circumstances surrounding the imposition of the 3520 penalties. The attorney will need to understand the details of your case in order to determine whether there are grounds for an appeal.

2. Prepare a written statement outlining the reasons for the appeal. This statement should include all relevant facts and legal arguments in support of the appeal. The statement should be written clearly and concisely, providing the IRS with a detailed explanation of the reasons why the penalties should be abated.

3. File the appeal with the IRS. Depending on the specific circumstances of the case, the attorney will file the appeal with the IRS office that imposed the penalty or with the appropriate appeals office.

4. Respond to any requests for additional information from the IRS. The attorney will need to provide any additional documentation or evidence requested by the IRS in order to support the appeal.

5. Represent the client in any further proceedings, such as an appeals conference or a hearing before the Tax Court.

In some cases, the IRS may require a face-to-face meeting, called a "collection due process hearing" (CDP). During this meeting, the attorney may negotiate with the IRS and present a case for abatement of the penalties.

The appeal process can take a significant amount of time. You should consult with a tax attorney as soon as possible if you receive a 3520 penalty notice, to ensure that you meet the deadlines to file an appeal. The tax attorney will help you determine if abatement relief or a settlement is possible and will negotiate a resolution with the IRS.


IRS Form 3520: Reporting Foreign Trusts and Receipt of Large Gifts or Inheritances
Demystifying IRS Form 3520: A Comprehensive Guide
Form 3520: What Are The 5 Critical Steps for Reporting Foreign Gifts and Inheritances?
Received a Foreign Gift? File IRS Form 3520 or Face Significant Penalties.

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Form 3520 Penalty Relief and Abatement.

Focused Exclusively on Appealing Tax Penalties Arising From Late or Non-filing of Form 3520 & Form 3520-A.