SFOP & Form 8891 Election

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mstevens
Posts: 5
Joined: Sun Apr 19, 2020 2:56 pm

SFOP & Form 8891 Election

Post by mstevens » Tue Jun 02, 2020 6:56 pm

I'm working on a streamlined foreign offshore disclosure for a taxpayer's failure to report his FBAR & FATCA forms in any taxation year. He has a number of large RRIF's and I'm wondering if we ought to request for an extension of time to file an election with form 8891 (US Information Return for Beneficiaries of Certain Canadian Registered Retirement Plans).

I know the form is automatic now but since we are amending prior year tax returns I'm thinking this may be worthwhile to include in the submission. What do you think?

mstevens
Posts: 5
Joined: Sun Apr 19, 2020 2:56 pm

Re: SFOP & Form 8891 Election

Post by mstevens » Tue Jun 02, 2020 8:10 pm

Re-reading the forms per https://www.irs.gov/individuals/interna ... ted-states:

For returns filed under these procedures, retroactive relief will be provided for failure to timely elect income deferral on certain retirement and savings plans where deferral is permitted by the applicable treaty. The proper deferral elections with respect to such plans must be made with the submission. See the instructions below for the information required to be submitted to make such elections.

The answer seems to be: Yes.

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