Revenue Procedure 2014-55 provides that eligible U.S. citizens and residents with certain Canadian retirement plans will be treated as making an election under Article XVIII(7) of the U.S.-Canada Income Tax Treaty to defer U.S. income tax on income accruing in their retirement plans until a distribution is made. Such individuals will be treated as having made the election in the first year in which they would have been entitled to make the election under the treaty. This revenue procedure also eliminates a reporting requirement associated with such Canadian retirement plans.
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