The US Internal Revenue Service (IRS) issued Revenue Procedure 2020-17 on 2 March 2020 to provide an exemption from the information reporting requirements under section 6048 of the US Internal Revenue Code (IRC) for certain US citizens and resident individuals with respect to their transactions with, and ownership of, certain tax-favoured foreign trusts that are established and operated exclusively or almost exclusively to provide pension or retirement benefits, or to provide medical, disability, or educational benefits.
In addition, Revenue Procedure 2020-17 provides procedural guidance for certain eligible individuals on how to request abatement of penalties that have been assessed, or refunds of penalties that have been paid, for a failure to comply with the information reporting requirements regarding such foreign trusts.
Revenue Procedure 2020-17 is effective as of the date on which Revenue Procedure 2020-17 is published in the Internal Revenue Bulletin (i.e. 16 March 2020), and applies to all prior open taxable years, subject to the limitations of IRC section 6511.
Revenue Procedure 2020-17 will be in the IRS Internal Revenue Bulletin (IRB) as part of IRB 2020-12, dated 16 March 2020.