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  • Writer's pictureMilan Solarz-Patel

IRS Delinquent International Information Return Submission Procedures

Updated: Oct 16, 2023

What do you do if you have a delinquent international information return?


Taxpayers who have identified the need to file delinquent international information returns who are not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the delinquent information returns through normal filing procedures. Penalties may be assessed in accordance with existing procedures.


  • All delinquent international information returns other than Forms 3520 and 3520-A should be attached to an amended return and filed according to the applicable instructions for the amended return.

  • All delinquent Forms 3520 and 3520-A should be filed according to the applicable instructions for those forms.

  • Taxpayers may attach a reasonable cause statement to each delinquent information return filed for which reasonable cause is being asserted. During processing of the delinquent information return, penalties may be assessed without considering the attached reasonable cause statement. It may be necessary for taxpayers to respond to specific correspondence and submit or resubmit reasonable cause information.

Information returns filed with amended returns will not be automatically subject to audit but may be selected for audit through the existing audit selection processes that are in place for any tax or information returns.

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