Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) is only required to be filed if you were the recipient of a gift(s) from a foreign national(s) in annual excess of $100,000, or if you were the owner of a foreign trust account or entity, or had financial interactions with such a foreign trust.
It does not apply to any other foreign bank or financial accounts, or to the many other circumstances that a US taxpayer may have, or encounter, with overseas financial transactions.
For the specific example of your case, if you simply moved money from a US-based account into a foreign account (or from one foreign account to another), and that process did not involve a trust entity organized under the laws of a foreign country, then you have no filing obligation for Form 3520.
However, assuming that you own a bank
account or maintain other financial assets in a foreign country, there are certain other foreign financial account
reporting requirements that you must meet, in addition to filing a
primary tax return (Form 1040, etc., and aside from Form 3520.
In fact, there are two
separate disclosure forms that may be required for foreign accounts; each also has different
reporting rules. One is known as IRS Form 8938, and can be
attached to the taxpayer's relevant yearly Form 1040 tax return. The other is FinCen
Form 114, which can only be filed via the internet. The following
Internal Revenue Service webpage describes them in some detail, and provides
their dollar value reporting levels:
https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements
Form 8938 is included in
TurboTax. FinCen Form 114 is not included in TurboTax, and you would need
to access that reporting webpage separately, if your foreign financial assets
total over the limit(s). Note that you can get to the FinCen reporting
internet site directly through the above IRS link.
Thank you for asking this important question.
