Federal Tax Controversy

Received a Form 3520 Penalty or Facing a Foreign Gift or Trust Reporting Issue?

Federal tax counsel for Form 3520 penalties, late or missed filings, foreign gifts and bequests, foreign trust transactions, and related IRS disputes.

Complimentary Initial Case Screening

Limited to conflicts, matter fit, and potential engagement. Substantive legal advice is provided only after engagement.

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Washington, D.C. Office

800 Connecticut Avenue, N.W.
Suite 300
Washington, D.C. 20006

Direct: +1 202-870-1977

Tysons Office

1750 Tysons Boulevard
Suite 1500
McLean, Virginia 22102

Direct: +1 703-403-1488

Form 3520 disputes can arise from foreign gifts or bequests, transactions with foreign trusts, distributions from foreign trusts, ownership of foreign trusts, or late and incomplete international information reporting. Chase Counsel evaluates the reporting history, IRS notices and penalty assessments, reasonable-cause issues, related Form 3520-A obligations, and available administrative or judicial remedies.

Selected matters only. The firm does not provide routine tax-return preparation services.

Attorney Chase Sizemore, JD, LLM

Principal, Chase Counsel PLLC

Georgetown Tax LLM | Former KPMG Auditor

U.S. Tax Court | Columbia University Graduate Studies

National Institute for Trial Advocacy (NITA) Diploma

30+ Years of Legal Experience

When an international reporting mistake produces an IRS penalty, the issue is no longer tax preparation. It is representation.

What We Handle

Form 3520 Penalty Notices

IRS penalty assessments arising from late, incomplete, or disputed Form 3520 reporting.

Late or Missed Form 3520

Evaluation of late or missed filings, reporting history, corrective options, and potential penalty exposure.

Foreign Gifts & Bequests

Form 3520 matters involving reportable gifts or bequests received from certain foreign persons or foreign estates.

Foreign Trust Transactions

Reporting and controversy matters involving transfers to foreign trusts and other transactions subject to Form 3520 reporting.

Foreign Trust Distributions

Form 3520 matters involving distributions or deemed distributions received by U.S. persons from foreign trusts.

U.S. Owners & Form 3520-A

Matters involving U.S. ownership of foreign trusts, Form 3520-A obligations, substitute Form 3520-A filings, and related penalties.

Reasonable-Cause Penalty Defense

Analysis and presentation of reasonable-cause positions in appropriate Form 3520 and foreign-trust penalty matters.

IRS Appeals & Penalty Disputes

Administrative challenges, penalty disputes, IRS Appeals matters, and related federal tax controversy proceedings.

Selected matters only. The firm does not provide routine tax-return preparation services.

Request an Initial Case Screening

Before you hire a lawyer, know who you are actually hiring.

Why Clients Choose Chase Counsel

Georgetown Tax LLM | U.S. Tax Court | Former KPMG Auditor | Columbia University Graduate Studies | 30+ Years of Legal Experience

Chase Counsel is not a high-volume tax-resolution practice.

Attorney Chase Sizemore personally evaluates and leads each matter, drawing on more than thirty years of legal and advisory experience. He earned an LLM in Taxation from Georgetown University and previously worked as an auditor at KPMG. He is admitted to practice before the United States Tax Court, completed graduate studies at Columbia University, received advanced trial-advocacy training through the National Institute for Trial Advocacy, and has nearly two decades of professional experience in South Korea and China.

Outside his law practice, he founded and leads Teach Them To Fish Foundation, which builds and supports primary schools in rural Cambodia and Uganda for vulnerable children, with particular emphasis on girls' education. His humanitarian service has been recognized with the U.S. Presidential Lifetime Achievement Award, the Royal Order of Cambodia medal, and eight Cambodian Sthapana Cheat gold medals.

His published and forthcoming work includes the legal treatise Nonprofit Stewards, the memoirs The Road to Kitgum and Where the Red Earth Broke, and numerous legal and scholarly articles.

Speak With Federal Tax Counsel

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Call to discuss your Form 3520 or international tax matter and how we may be able to help.

Call (703) 403-1488

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