In Revenue Procedure 2020-17[1] the IRS provided an exemption from information reporting rules under IRC §6048 for transactions with or ownership of certain specified tax-favored foreign trusts.

Under IRC §6048, U.S. persons are required to file annual reports for:

• Transfers of money or other property to a foreign trust;

• Ownership of a foreign trust; or

• Distributions from a foreign trust.

The information reporting for §6408 is provided for on:

• Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and

• Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)).

IRC §6077 imposes significant penalties on taxpayers who fail to file these reports.