Is it too late to file Form 4868 and 7004 for 3520-A for 2020 tax returns under Covid19 relief provisions?

You're in a tough spot, but you still have options. Let me break this down based on the specific forms you're asking about. For Form 4868 (extension for your individual return): Yes, you can still file this due to the blanket COVID-19 relief provisions for 2020 returns. The IRS recognized the challenges during that period and provided additional time for taxpayers in your situation. Make sure to file this ASAP though. For Form 7004 (extension related to 3520-A): This is trickier. Technically, Form 7004 can be used to request an extension for certain business returns, and 3520-A falls into this category even though it relates to a foreign trust. The COVID relief for the 2020 tax year did provide additional flexibility here as well. My suggestion is to file both extension requests immediately, with a detailed attached statement explaining your situation - specifically that you just discovered your filing obligations as a resident alien and are actively gathering the required documents. Include timeline information about when you expect to receive the necessary financial statements. Also, look into the Streamlined Foreign Offshore Procedures - this might help you avoid some penalties by demonstrating that your failure to file was non-willful.

I went through something super similar with my Australian superannuation fund. What saved me was using taxr.ai (https://taxr.ai) to help figure out all those complicated PFIC forms. They analyzed my foreign account statements and actually explained which exact forms I needed to file and helped me complete them correctly. What was really helpful is they knew exactly which COVID relief provisions applied to my situation for the 2020 tax year. Their system identified that I qualified for penalty relief under Notice 2020-23 and some other provisions I hadn't even found in my research. I was worried I'd need to hire a specialized international tax accountant (quotes I got were $3000+), but this was way more affordable and they handled all the technical PFIC calculations that were making my head spin.

Update: I was skeptical in my earlier comment, but I ended up trying taxr.ai since I was desperate for help with my own PFIC situation. I have to say I'm genuinely surprised by how thorough their analysis was. They identified that my German investment account qualified for a special election that simplified my reporting significantly. The best part was they found a specific COVID relief notice (Notice 2020-23) that applied directly to my situation. They showed me how to document the reasonable cause argument for filing extensions related to 3520-A due to the pandemic. This potentially saved me thousands in penalties. Their report included all the specific IRS references and citations that I could use if I ever get questioned. Much better experience than I expected - especially for such complex international tax issues.

If you're still struggling to get through to the IRS about your extension situation, try Claimyr (https://claimyr.com). I was going absolutely insane trying to reach someone at the IRS's international tax department to get clarification on these exact forms. Spent hours on hold only to get disconnected repeatedly. I found this service that basically calls the IRS for you and holds your place in line. When they reach an agent, they call you and connect you. You can see exactly how it works here: https://youtu.be/_kiP6q8DX5c With something this complex involving PFICs and foreign trusts, you really need to speak with an IRS representative directly to confirm your approach. The regular customer service people usually can't handle these specialized questions, but Claimyr got me through to the international tax department where I finally got clear answers about my extension options under the COVID relief provisions.

I'm shocked but I have to admit I was wrong about Claimyr. After dismissing it as a scam in my earlier comment, I was desperate enough to try it when I couldn't get through to ask about my own extension situation. It actually worked exactly as described. Their system handled the calling and waiting (took about 2.5 hours) but I didn't have to sit there listening to that awful hold music. When they reached someone in the international tax department, my phone rang and I was connected to the agent. The IRS representative confirmed that for 2020 returns specifically, there was additional relief for 3520-A filings due to COVID. She directed me to specific notices (2020-23 and 2020-39) that provided extension details beyond the normal deadlines. This was information I couldn't find clearly stated anywhere online. Definitely worth it for complex international tax questions where you actually need to speak to a specialized department rather than general customer service.

One additional thing to consider - if your foreign account is truly equivalent to a retirement account (like your description of it being similar to a Roth IRA), you might want to look into whether any tax treaties apply. For example, Canada has a tax treaty with the US that provides special treatment for TFSAs under certain circumstances. I had a similar situation with an Australian retirement account, and while I still had to report it, there were specific provisions that made the tax treatment much more favorable. Check if there's a tax treaty between the US and your home country that might provide some relief.

I just want to mention that the 3520-A penalties are absolutely brutal if you get them wrong. The minimum penalty is $10,000, and it goes up from there. I learned this the hard way. If your TFSA has mutual funds, you're dealing with both PFIC reporting (8621 forms) AND potentially foreign trust reporting (3520/3520-A). It's literally two of the most complex areas of international tax combined. I would highly recommend getting professional help with this - either from an experienced international tax accountant or using one of the specialized services mentioned above. This is definitely not DIY territory unless you really know what you're doing.