Guidance on Form 8938 with respoect to RRSPs

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rafa02
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Post by rafa02 »

nelsona, with all due respect, it occurs to me that you may be over thinking this, and/or playing devil's advocate, which is fine, it is good to be thorough and consider various possibilities; however, what in the 8938 instructions, would cause you to think the RRSP needs to be reported with individual holdings?

I do not see the requirement to report individual holdings, merely to report the details of the RRSP. The details are the description is Canadian RRSP, the account # is the account #, the name of the issuer of the RRSP is the fininancial institution holdin g the RRSP, and the address and the max value during the year - those are the details. Where does it indicate otherwise?
nelsona
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Post by nelsona »

What do you think? I aim for consistency in filing for all on this site. So I want to make it clear what needs to be done and should be followed.

Why are you not reporting individual holdings.? What is your reason, other than you don't think IRS wants this? When have you been reporting individual assets, since the examples CLEARLY show individual assets are reportable in some cases.
I am taking my usual break from this site until May. Always too many tax-form specific questions at this time of year...
nelsona non grata. Non pro. Search previous posts. Happy Browsing :D
rafa02
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Post by rafa02 »

OK, I will wait andhopefully a bit more clarification will be forthcoming.

As always, thanks for your efforts.
nelsona
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Post by nelsona »

The thing to consider is that NO ONE has yet reported an RRSP on 8938 without using the 8891/3520 exception.
I am taking my usual break from this site until May. Always too many tax-form specific questions at this time of year...
nelsona non grata. Non pro. Search previous posts. Happy Browsing :D
testone
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Post by testone »

Rev. Proc. 2014-55, the Revenue Procedure that eliminates the 8891, in section 5.01 says that no 3520 or 3520-A is required for an RRSP.
testone
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Post by testone »

Sorry, thought you were asking a different question. Please disregard my prior post.
marge
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Joined: Mon May 09, 2005 1:26 pm

Post by marge »

I'm an American citizen, Canadian resident, dual tax filer.

I found the following, on pages 4-5 of the new Instructions for Form 8938 (2014):
"[b]Interests in assets held in financial accounts.[/b] If you have an interest in a financial account that holds specified foreign financial assets, you do not have to report the assets held in the account."

I would take this to mean that if I have an RRSP with a Canadian financial institution, I report the maximum fair market value of the whole RRSP and the account number, but not the individual assets inside the account. Also, if I have no income from the RRSP during the year, this would be the extent of the reporting requirement regarding the RRSP, i.e. no other form would be necessary.

Is this correct?
nelsona
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Post by nelsona »

That sounds correct.
And which section(s) are you reporting these in?
I am taking my usual break from this site until May. Always too many tax-form specific questions at this time of year...
nelsona non grata. Non pro. Search previous posts. Happy Browsing :D
marge
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Joined: Mon May 09, 2005 1:26 pm

Post by marge »

Part V!. for the RRSPs details, Part II for the summary of RRSP holdings. No earnings to report, therefore nothing to fill in, in Part III 2).

Bank accounts, and investments outside of RRSPs, should be summarized in Part I, and the account details given in Part V, I presume. Also, any earnings should be reported in Part III, 1) I believe, with the schedules, like Schedule B for interest and dividends, indicated in the applicable "where reported" column?

I'm not clear on "deposit" vs "custodial" accounts. Would a savings account be a "deposit" account, and an investment account managed by an investment company be a "custodial" account?
acd257
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Joined: Thu Jan 24, 2008 7:15 pm

Post by acd257 »

As per 8938 instructions we need to enter in RRSP info in Part VI line 1 thru 6 and line 8. My RRSP are with Investor Group in Canada. My question for line 8 a is it Issuer or Counterparty and 8b what type I need to select (1)individual or (2) partnership or (3) corporation etc
taxeve
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Location: Montreal, Canada

Post by taxeve »

[quote="acd257"]As per 8938 instructions we need to enter in RRSP info in Part VI line 1 thru 6 and line 8. My RRSP are with Investor Group in Canada. My question for line 8 a is it Issuer or Counterparty and 8b what type I need to select (1)individual or (2) partnership or (3) corporation etc[/quote]

Re: Form 8938 Part VI: I have the exact same questions regarding Investors Group. Answers to those 2 questions would be most appreciated. Many thanks.
MGeorge
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Joined: Fri Jun 22, 2012 9:23 am
Location: Canada

Post by MGeorge »

Hello,

I wasn't sure about line 8 either. I think counterparty is the best fit. I said that my CIBC Investor's Edge RRSP was a "corporation".
I struggled with this because an RRSP is also a Canadian trust - but I think in this context they are asking what "CIBC Investor's Edge" is - they are a corporation not a trust.

how many agree with what I did?
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MGeorge is neither an accounting nor taxation professional.
voribo
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Post by voribo »

I think some of the problem using Part VI is that it does not fit RRSPs very well as RRSPs are financial accounts ( as is clearly called in the Fincens/FBARs) yet Part VI is for assets not held in a financial account..... go figure...see:

Part VI. Detailed Information for
each "Other Foreign Asset"
Included in Part II Summary
Use Part VI to report information for
specified foreign financial assets not
held in a financial account

I still have a few months to finalize how to fill out the form.
no-pro
K104XYZ
Posts: 18
Joined: Sun May 18, 2014 11:05 am
Location: Calgary AB

Post by K104XYZ »

MGeorge,

For my RRSP reporting in Part VI of Form 8938, I have reported my RRSP accounts “in wholeâ€￾ just like they had been reported on Form 8891 in previous years (that is, one Part VI report for each RRSP account).

I described “the assetâ€￾ on Line 1 as being a Canadian RRSP.

For Line 8 items, I included the name and address of the RRSP plan custodian, just like had been reported on Form 8891 previously.

Under Line 8a, I showed the plan custodian as being the “issuerâ€￾, while you showed it as being the “counterpartyâ€￾, so we’re a bit apart on that one.

On Line 8b, I showed “corporationâ€￾ just like you did, for the same reason as you said. I have seen other advice on the internet that suggested that Line 8b should say “trustâ€￾ because an RRSP is a trust – however, my plan custodian is a corporation, as I see it, just like you said.

According to the official terminology used by the CRA, the RRSP plan custodian is referred to as "the issuerâ€￾ of the RRSP. I realize that that doesn’t mean much when filing an IRS form, but it did influence me to some extent in making my selection of “issuerâ€￾ in the face of ambiguity.

As well, since I didn’t want to get into “any possibilityâ€￾ of having to break my RRSPs down into separate Part VI reports for each individual financial product in each RRSP, I thought it would be better to say that the RRSP custodian was the “issuerâ€￾ of the RRSP (“the assetâ€￾ on Line 1), because I figured if I said “counterpartyâ€￾ it could possibly invite questions about who any of the other parties might be.

Anyway, that’s just my personal take on it. In the absence of clear instructions or definitions, it seems open for interpretation.
MGeorge
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Joined: Fri Jun 22, 2012 9:23 am
Location: Canada

Post by MGeorge »

Hi K104XYZ,

Thanks for your guidance on this one. I will go with issuer as well. I'm starting to realize that there is no new information that we didn't already report on form 8891 - except for the fact that they want the peak account value instead of the end of year value. Other than that - it isn't too bad.

Cheers.
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MGeorge is neither an accounting nor taxation professional.
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