Beneficiary of RESP

[rockbottom]

Forgive my continued ignorance, but I'm trying to work out this dilemma. As the grantor of an RESP, I understand I must file 3520/2520A's for all years it was in existence. I'm working with an accountant on that.

What do I do for the beneficiary though?

The RESP was cashed in 2011 and my daughter received the money. I now understand that we should have filed a 3520 for her also.

I'm entering the streamlined compliance program, but last year was the first year my daughter would have had to report anything.

This year, I helped her file a 2012 return, so she is in compliance going forward, but it disqualifies her from the streamlined procedure. Kicking myself over that.

When I do all my old returns it will expose her lack of reporting because she will be listed as the beneficiary. I could technically claim her as a dependent for 2011 as she was under nineteen and living at home. If I did that, could I report the RESP distribution as my income and file the 3520 on her behalf as part of my streamlined package?

Or should she late file (there will be no tax liability) with an explanation letter?

[rockbottom]

Also, is the entire distribution taxable in her hands?

The distribution would consist of about $3000 contributions, $800 CESG, and $100 interest.