Rev. Proc. 2014-55 and Canadian retirement plans
Rev. Proc. 2014-55 covers treaty treatment of certain Canadian retirement plans, eligibility for an election, and related U.S. reporting.
Election rules and eligibility
The procedure treats an eligible individual who had not previously elected treaty treatment as having made the election for the first year in which the individual could have elected for that plan. The procedure applies plan by plan, and the election continues through the year of a final distribution unless revoked with the Commissioner's consent.[1]
U.S. reporting and foreign accounts
The procedure distinguishes reporting relief for specific plans from other reporting requirements that may apply to a foreign financial asset or account. An RRSP interest may be reportable under section 6038D or another provision, and separate FinCEN Form 114 filing requirements may also apply. Separate reporting obligations may still apply despite treaty treatment.[1]
Where to find the official text
The official text appears in the Internal Revenue Bulletin, in the entry beginning with Rev. Proc. 2014-55.
Related reading
Publication 901 (09/2024), U.S. Tax Treaties provides broader treaty context, while 26 U.S.C. § 6048, Foreign trust information covers the reporting framework. Rev. Proc. 2020-17 and foreign trust reporting covers a separate procedure addressing specified tax-favored foreign trusts. IRS Foreign Trust Reporting Requirements provides a broader reference to foreign trust reporting.
Questions and answers
Where is the official text published?
The procedure appears in the Internal Revenue Bulletin under Rev. Proc. 2014-55.
Related resources
Related glossary terms
- Income tax treaty: An income tax treaty may provide reduced U.S. tax rates or exemptions for specified U.S.-source income. Rules vary by country and income type under each treaty.
- Limitation on benefits: A limitation on benefits article sets conditions for entities in a treaty country to qualify for certain treaty benefits under the applicable U.S. tax treaty.
- Section 679: Section 679 addresses certain transfers by U.S. persons to foreign trusts. It treats some property transfers as ownership when the trust has a U.S. beneficiary.
Related articles and guides
- Rev. Proc. 2020-17 and foreign trust reporting: Rev. Proc. 2020-17 covers its scope, trust definitions and eligibility conditions, and its link to U.S. reporting for certain foreign trusts and U.S. persons.
- Rev. Rul. 2008-40, Foreign Trust Transfers: Rev. Rul. 2008-40 is an IRS ruling on transfers from certain qualified retirement plans to foreign trusts and Puerto Rico plans, and income inclusion.
Tools and official documents
- IRS and FinCEN forms: reference pages: Reference pages for 15 IRS and FinCEN forms tied to foreign trusts, foreign accounts and entities, built from the official forms and their instructions.
- IRS form finder: Search form reference pages by keyword or number. Each result has a one-line description, and matches run across form titles and numbers, plus descriptions.
Related pages
Sources and data notes
- U.S. Government, Relief from Certain U.S. Tax Rules for Certain Canadian Retirement Plans. https://www.irs.gov/pub/irs-irbs/irb14-44.pdf. Retrieved .
Dates in this block record when each source was read for this page.