It is rumored that an attorney in Texas has applied for a private letter ruling on behalf of a client asking for a ruling from the IRS that an owner of a property held in a Fideicomiso does not have to file forms 3520 and 3520A. Private letter rulings are only binding on the IRS with respect to the individual taxpayer who requested it, though sometimes the IRS will apply them to everyone. That ruling is expected to be released within the next month and finally for the first time there will be an IRS written declaration on filing requirements for Fideicomisos.
