On June 6, 2013, the Internal Revenue Service issued Revenue Ruling 2013-14, which concludes that a Fideicomiso or a Mexican Land Trust (MLT) is not taxed as a “trust” for U.S. income tax purposes. While most practitioners...more
On June 6, 2013, the IRS released Revenue Ruling 2013-14, which holds that Mexican fideicomisos or Land Trusts are not trusts for U.S. tax purposes. “Fideicomisos have been an issue in the offshore disclosure world for quite...more