Rev. Rul. 2013-14

(Mexican Land Trusts utilized by U.S. citizens to hold ownership interests in residential real estate in parts of Mexico are not "trusts" for purposes of Treas. Reg. Sec. 301.7701-4(a); thus, there is no need to file Form 3520 and penalties for failure to file are not applicable;  follows Priv. Ltr. Rul. 201245003 (Jul. 30, 2012)).