Rev. Proc. 2020-17, page 539.

This revenue procedure exempts from section 6048 information reporting requirements certain U.S. individuals’ transactions with, and ownership of, certain tax-favored 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, this revenue procedure provides procedural guidance for certain eligible individuals on how, subject to sections 6511 and 6402, to request abatement of penalties that have been assessed, or refunds of penalties that have been paid, pursuant to section 6677 for a failure to comply with the information reporting requirements of section 6048 regarding these foreign trusts.