International Tax Blog

Fideicomisos/Mexican Land Trusts are Not Trusts (Finally)

As a follow up to our post earlier this year regarding a private letter ruling that concluded that a fideicomiso (or Mexican Land Trust) was not a trust for U.S. tax purposes, today the I.R.S. published Rev. Rul. 2013-14 which concludes the same. Although a taxpayer cannot rely on a private letter ruling, taxpayers can rely on revenue rulings. This ruling should now allow many taxpayers who have been filing Form 3520 for their Mexican... Read more →

I.R.S. Rules that Mexican Fideicomiso is Not a Trust

Update: June 7, 2013 - See IRS issues Rev. Rul. on Fideicomisos Yesterday the I.R.S. released PLR 201245003, which concluded that a Mexican fideicomiso (or Mexican Land Trust) was not a trust for U.S. tax purposes. If a Mexican fideicomiso is not a trust, then it is not a foreign trust and no Form 3520 or 3520-A would need to be filed. In the ruling, a U.S. corporation (“X”) was formed that was owned by... Read more →