
FORM 3520 / 3520A NOT REQUIRED FOR CERTAIN TAX FAVORED FOREIGN TRUSTS
By: Lynn K. Ching Certain Tax Favored Foreign Trusts Exempt From 3520/3520A Reporting Under (recently issued) IRS Revenue Procedure 2020-17 (“Rev Proc 2020-17”), certain U.S. persons having an interest in qualifying tax-favored foreign trusts established and operated exclusively or almost exclusively to provide pension or retirement, medical, disability, or educational benefits are exempt from Forms 3520 and 3520-A reporting. The IRS and Treasury determined that because certain tax favored trusts are subject to written requirements under foreign local law (such as contribution limits, withdrawal limitations, and informational reporting), it would be appropriate to exempt U.S. individuals from the requirement to provide information about these trusts under IRC Sec. 6048 Only Eligible Individuals May Rely on Rev Proc 2020-17 For purposes of Rev Proc 2020-17, an eligible individual means an individual…