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Do U.S. Taxpayers with a Canadian RRSP or RRIF Need to File Form 3520?

In most cases, U.S. taxpayers who own a Canadian Registered Retirement Savings Plan (RRSP) or Registered Retirement Income Fund (RRIF) do not need to file Form 3520 due to a special IRS exemption.

IRS Exemption from Form 3520 for RRSPs & RRIFs

  • The IRS Revenue Procedure 2014-55 eliminated the requirement to file Form 3520 or Form 3520-A for Canadian RRSPs and RRIFs, provided that:
    • The U.S. taxpayer makes an election to defer U.S. taxation of earnings inside the RRSP/RRIF under Article XVIII(7) of the U.S.-Canada Tax Treaty.
    • The election is reported on Form 8891 (prior years) or now on Form 8833.