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 →