Look, employer contributions were NEVER taxable in US. Period.. Forget about that part. The RP (and indeed all IRS rules regarding pensions only talk about pension INCOME, because that is the only thing that ever was taxable. All that has chnged, from time to time, as I said at he outset, was REPORTING rules, NEVER taxable contribution rules.
RP 02-23 has been suprceded by Form 8891, which applies ONLY to RRSPs/RRIFs.
No one, even those who once submitted RP 02-23 statements for their RPPs, is still doing this.
The history of the development of Form 8891 is coverd in many posts here and on grasmick.com
I'm done on this one. Happy browsing.
Your accountant, since he believes something has to be submitted to IRS, must know what it is, since most have a pension, and he being an expert and all. Do as he says.
US tax on pension plan contributions and earnings
Moderator: Mark T Serbinski CA CPA