AICPA Foreign Trust Comments:
- May 2013 Sample IRS Letter to Taxpayer on Form 3520 has been processed.
- May 8, 2013 AICPA comments to IRS on Medicare surtax and trusts and estates, including foreign trusts.
- IRS responding (update as of Dec. 4, 2012, and October 18, 2012) to AICPA letter on IRS systemic incorrect letters
- August 28, 2012 AICPA letter to IRS on systemic IRS incorrect letters on Form 3520 reporting, including redacted letters to item 1, item 2, item 3, item 4, item 5, and item 6
- June 26, 2012 AICPA letter to IRS on decanting of trusts, including foreign trusts
- March 28, 2011 AICPA letter to IRS on foreign trusts and HIRE Act
- November 19, 2010 AICPA letter to IRS on FBAR foreign trust issues
- November 16, 2009 AICPA letter to IRS on FBAR issues, including foreign trusts
- September 22, 2008 AICPA letter to IRS with sample draft forms for Form 1041NR for IRS consideration (including sample Form 1041NR and Schedules D, K, K-1, and J, and Form 1041NR-T and Form 4970FT)
- June 12, 2008 AICPA comments to IRS on foreign trust issues - follow-up to IRS response to March 3, 2008 comments
- March 3, 2008 AICPA comments to IRS on foreign trust issues - follow-up to IRS response to Jan. 31, 2007 comments
- March 3, 2008 AICPA letter to IRS on foreign gift reporting threshold for reporting on Form 3520
- January 31, 2007 AICPA comments to IRS on foreign trust issues and suggestions
- June 17, 2003 AICPA comments to IRS on foreign trust Form 3520-A issues and suggestions
2010 HIRE Act Legislation on Foreign Trusts:
- AICPA letter to IRS on foreign trusts and HIRE Act
- Summary of Foreign Trust Provisions in the HIRE Act
- Article/Guide on Foreign Trust Provisions in the HIRE Act
AICPA Resources:
- AICPA Checklist on Foreign Trust Forms 3520 & 3520A
- Flowchart on 2011 Form 8938 Compliance for Individuals with Interests in Trusts and Estates
- Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part I) (The Tax Adviser)
Other Resources:
Mexican Land Trusts:
PLR 201245003 (July30, 2012) on Mexican land trust
Fideicomisos: Clarity at Last (11/12)
IRS Holds Mexican Land Trust Needs Foreign Trust Reporting (includes copy of PLR, Feb. 2012)
Own Property out of the US? (6/12)
Fideicomiso (Mexican Land Trust) Found to be Mere Agent of U.S. Taxpayer, Rather than Trust, in Private Letter Ruling (11/12, Arizona Society of CPAs)