RRIF contrib for US tax: 1st 60 days rule & "yr of

[Filo]

Hello,

In compiling a history of past contributions to my RRIF for US tax purposes, I have a question about which year I attribute a contribution to.

Example: in July 1993 I contributed $1000 to an RRSP; in February 1994 I contributed $2000 to the same RRSP. For Canadian taxes, that produced a $3000 contribution for the year 1993. (And in fact I treated it that way also for the US Rev. Proc. 89-45 form.) For the contribution history for US tax on RRIF withdrawals, I could now treat this in either of two different ways:

(a) 1993 contribution = $3000 x exch rate
or
(b) 1993 contribution = $1000 x exch rate;
and 1994 contribution = $2000 x exch rate.

It seems to me that (b) would be safer to avoid problems with the IRS.
Is that correct?

[nelsona]

IRS does not ask for detailed contribution times. They are only intersted in the "investment in the contract". The year doesn't matter.

Of couse, if you have been filing 89-45 forms since back, you already have an IRS approved history of contributions for all these years (in then current USD), so why the concern about re-calculating now?

[Filo]

==> The year does matter: that's what determines the exchange rate used. <==

The 89-45s: I did them wrong. The 89-45s only required an updated *total* contribution, and every year I took the *cumulative* Canadian-dollar contribution and then multiplied it by the current year's exchange rate. That's wrong.

When I telephoned the IRS the year the 89-45s came out, I actually got to talk to the fellow whose name was listed as the author of the 89-45. (He said he wasn't really the author.) He didn't rush me, but he essentially gave me no practical advice on how to fill out those (homemade) forms. I know that's no excuse; but I can't use the 89-45s for anything now.

[nelsona]

That is not correct. Your 89-45's were accepted.

The exchange rate fluctiation is not worth the retracing at this point.