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Posted

Client bought a house in Mexico through a Fideicomiso (Spanish for "Trust"). From my research, this seems to be a "grey area" in the law as to filing requirements, but I want to play it safe. (I wanted to bail on it completely but client couldn't find any other preparers with expertise in this area. And she's family ... )

I'm having trouble with Line 7 on Page 3 (Foreign Grantor Trust Owner Statement)

-- Attach an explanation of the facts and law (including the section of

the Internal Revenue Code) that establishes that the foreign trust (or

portion of the foreign trust) is treated for US tax principles as owned

by the US person. --

I'm already attaching the Fideicomiso per Part I Line 2b. The document

will specify the owner. Do I need to include anything else? I'm not familiar with what section of the IRS code says something like "hey, the document says you own it & since you are a US citizen, the trust is owned by a US person." But I'm probably reading this wrong!

Thanks!

Posted

A tax attorney I spoke with regarding foreign retirement accounts said they and the Fideicomiso were the biggest areas on noncompliance he fixes. So I'd say, no grey area, it is a foreign trust.

Posted

Thanks Joan.

I want to file them to play it safe. The 3520A was sent without any direct answer to the Line 7 question in my OP. The 3520 is done but has not yet been mailed. Would this tax attorney mind if I asked some questions to make sure I file these correctly? I also want to make sure I am completing all necessary documents. I'm only using the 3520A & 3520, and not the 1041 or FBAR.

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