Yesterday, March 2, the IRS has provided a long-awaited relief from reporting on Form 3520-A and 3520 and associated penalties to dual U.S./Canadian citizens and Green card holders with certain “tax-favored foreign” arrangements. Rev. Proc. 2020-17 discusses eligible U.S. citizens and residents, eligible “tax-favored foreign retirement and nonretirement” arrangements (referred to in the revenue procedure as “trusts”), provides a procedure for claiming a refund of assessed penalties, and requests further comments from the tax community. The IRS guidance can be found here: https://www.irs.gov/pub/irs-dr
Stay tuned for additional information during our special edition ad-hoc webinar next Tuesday.