IRS practice units: Foreign tax redeterminations; failure to file Form 3520/3520-A penalties

IRS examiner “job aides” and training materials

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May 1, 2025

The IRS Large Business and International (LB&I) division today released two “practice units”—part of a series of IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions:

  • Foreign Tax Redeterminations—This “concept unit” updates the June 3, 2021, practice unit with the same title. The update provides some clarifying narrative as well as removing items of reference that are obsolete.
  • Failure to File the Form 3520/3520-A – Penalties—This “process unit” replaces the practice unit with the same title dated September 16, 2015. The practice unit was updated for Revenue Procedure 2020-17 and Proposed Treasury Regulation 1.6048-5 as well as some updates to referenced resources.

The practice units are available on the IRS practice unit webpage.

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