Reporting for RRSP GIC on Form 8938 and FBAR

[mburnette]

Hi,

I'm a Canadian working in the US on a TN visa and required to file both Form 8938 and FBAR. I have an RRSP Savings account (as well as an RRSP brokerage account) that were opened before I moved to the US and I've been reporting both accounts separately under Part VI "Other Foreign Asset" on Form 8938 and "Other" category on FBAR for the past few years. Last year, I opened a 5-year RRSP GIC using the funds in my RRSP savings account and because its a bank GIC, the GIC has a different/new account number.

I'm unsure how to proceed with Form 8938 and FBAR. Should I a) report the RRSP GIC separately and mark it as a new account, or b) don't list RRSP GIC separately and report the aggregated total (RRSP Savings + RRSP GIC) under the RRSP Savings account ?

I'm reluctant to go with (a) because it will appear as if 1) i made an RRSP withdrawal on the savings account, 2) contributed to RRSP in the new account, and 3) Per Form 8938 instructions, it says "... Do not separately report the assets held by the plan." Because my RRSP GIC is funded by the money in RRSP Savings acct and will payout to the same account at maturity, it technically is just a form of investment held under the Savings account.

Thanks for any help regarding this.

[Cdninga]

I don't think the IRS cares what in the RRSP, they only want the see the total funds parked outside the US. I'd continue to submit the aggregate amount in the RRSP and not break out the GIC separately.

[Butheka89]

According to the instructions for Form 8938, you should not separately report the assets held within an eligible retirement plan, which includes RRSP accounts. Instead, you should report the maximum value of the RRSP accounts as a whole. This means you would aggregate the value of both your RRSP Savings account and the RRSP GIC and report the total value on Form 8938.

[pteesh]

RRSPs are foreign financial assets that must be disclosed on Form 8938, should you be obligated to submit this form. There exist several approaches that are only marginally acceptable in nature to rectify the situation in the event that the filing deadline for this has passed.

[Ezekieleard]

The amount of money held outside of Canada is what the IRS is interested in seeing, not the contents of an RRSP. In my opinion, it is more efficient to keep the total money in the RRSP rather than to separate out the GIC.