Today the IRS released Revenue Procedure 2014-55, which provides that eligible US citizens and residents with certain Canadian retirement plans will be treated as making an election under Article XVIII(7) of the US-Canada Income Tax Treaty to defer US 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.  The guidance also eliminates the requirement to report “contributions to, distributions from, and ownership of a Canadian retirement plan” under the previous simplified reporting required under Notice 2003–75.

The revenue procedure will appear in IRB 2014-44 dated Oct. 27, 2014.