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Internal Revenue Bulletin:  2014-44 

October 27, 2014 

TAX CONVENTIONS


Table of Contents

Rev. Proc. 2014–55Rev. Proc. 2014–55

This revenue procedure provides that eligible U.S. citizens and residents with certain Canadian retirement plans will be treated as making an election under paragraph 7 of Article XVIII 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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