Revenue Procedure 2002-23 provides
guidance for the application by U.S. citizens and residents of the
U.S. - Canada Income Tax Treaty, as amended by the 1995 protocol,
in order to defer U.S. income taxes on income accrued in certain
Canadian retirement plans. This revenue procedure was superseded by
Revenue Procedure 2014-55, published in the Internal Revenue
Bulletin dated October 27, 2014.
US Code:
26
USC 6103 Name of Law: Confidentiality and disclosure of returns
and return information
Rev. Proc. 2014-55 superseded
Rev. Proc. 2002-23. This new revenue procedure indicates an
eligible individual who did not previously make an election under
Article XVIII(7) of the Convention to defer current U.S. income
taxation on the undistributed income of a Canadian retirement plan
will be treated as having made the election in the first year in
which the individual would have been entitled to elect the benefits
under Article XVIII(7) with respect to the plan. Consequently, such
eligible individual will not be required to make the election for
that first year or for any subsequent years either on Form 8891 or
under the procedures set forth in Revenue Procedure 2002-23. Burden
estimates reflect the change in the requirement of this election
changing from first-time and annual to a first-time only
election.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.