On 3rd March 2020, the Internal Revenue Service (IRS) issued Revenue Procedure 2020-17 (Rev Proc), which specifically covered an exemption from information reporting in respect of certain non-US retirement plans. To provide some context, US persons with an interest in a non-US “trust-based” retirement plan should consider filing Forms 3520-A and 3520 annually in respect […]

US settlors and US beneficiaries of non-US trust face a myriad of US income tax and reporting obligations that are not imposed on US settlors and US beneficiaries of US trust. In the first instance, both settlors and beneficiaries must report the income and gains of the trust allocated to them on their US income […]