Group RRSP/ DPSP and form 8891 filing question?

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boogens8
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Location: vancouver, bc

Group RRSP/ DPSP and form 8891 filing question?

Post by boogens8 »

Hi,

I've read through the forums, but can't find an answer to my specific RRSP/DPSP US reporting requirements question:

I am a US citizen working in Canada for a Canadian company.

Through my work I have a Group RRSP plan, which includes a DPSP plan where the employer contributes a match to my RRSP contribution. I have made no withdrawals.

I plan to file US Form 8891 to report my RRSP account and to elect to defer taxation, but how do I report the DPSP plan? They are both with SunLife and both have the same account number.

-Do I file a separate 8891 for the DPSP, but listing the same account number again?
-Do I combine both balances into one lump sum and report that total on only one form?
-Or, am I supposed to report this type of DPSP some other way?

This is the first tax year where this is relevant for me, so I don't have any amendments to make for prior tax years.

There may be other information I need to provide to answer this throroughly, so please let me know.

Thanks in advance for your help,
nelsona
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Post by nelsona »

The DPSP is a pension account and need not be reported.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing :D
boogens8
Posts: 8
Joined: Thu May 17, 2012 7:45 pm
Location: vancouver, bc

Post by boogens8 »

Hi Nelsona,

Thanks for the reply. I do have a followup question. I had previously read through this RevProc 2002-23 from the IRS (which may be outdated now, but I'm not sure).

Section 3 below lists "deferred profit sharing plan", which is why I thought I would need to file an 8891, but is this a reference to some different type of DPSP, or is there something in the nature of my type of DPSP being a Canadian Pension Plan that exempts it from any reporting or tax deferral elections for the US, (like those in place for RRSPs).

I think some of my confusion is coming from my not knowing if there is only 1 type of a DPSP in Canada, or if there are multiple ways a DPSP can be registered in Canada, and then subsequently viewed by the IRS for tax purposes?

Thanks in advance for your time,


SEC. 3. SCOPE
This revenue procedure applies to an individual who is a citizen or resident of the United States and a beneficiary of one of the following Canadian plans (an “eligible planâ€￾): a RRSP, a RRIF, a registered pension plan, or a deferred profit sharing plan. This revenue procedure applies regardless of whether the individual was a resident of Canada at the time contributions were made to the eligible plan. For purposes of this revenue procedure, a “beneficiaryâ€￾ of an eligible plan is an individual who would, in the absence of an election under Article XVIII(7) of the Convention, be subject to current United States income taxation on income accrued in the plan. The revenue procedure applies only to income accrued in an eligible plan and not to any contributions to the plan.
nelsona
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Post by nelsona »

RPP and DPSPs are not addressed by 8891.

There has been no direction to file anything on pensions or DPSPs since that Rev Proc, which has for the most part been superceded.

If it makes you sleep better, you could submit a statement conforming toe RP 2002-23 for your RPP and/or DPSP, but we have not seen this as an issue in the intervening 10 years.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing :D
boogens8
Posts: 8
Joined: Thu May 17, 2012 7:45 pm
Location: vancouver, bc

Post by boogens8 »

Thanks very much, I think I'll sleep better either way now.
boogens8
Posts: 8
Joined: Thu May 17, 2012 7:45 pm
Location: vancouver, bc

Post by boogens8 »

Hi Nelson

I have another followup question:

If I were to submit a statement saying that I'm conforming to RP 2002-23 for my DPSP, would I do that on form 8833? And if so, would that be an election under either section 6114 or 301.7701(b)-7? (I am a US citizen working in Canada under a work permit)

I see that it's probably not necessary ultimately, but I feel that it would show good faith effort to the IRS that I am trying to report my DPSP, just if it ever became an issue in the future for some reason.

Thanks again in advance,
nelsona
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Joined: Wed Oct 27, 2004 2:33 pm
Location: Nowhere, man

Post by nelsona »

Your statement would be sufficient on its own, as per the instructions in the RP (which do not say to file the statement on 8833, do they). So, it is NOT to be made on 8833.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing :D
testone
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Post by testone »

It is interesting that the IRS comparison of the filing requirements for Form 8938 and the FBAR (http://www.irs.gov/businesses/article/0 ... 86,00.html) does not mention foreign pensions, such as DPSPs and RPPs. I would think that these types of accounts would need to go on both the 8938 and the FBAR.
testone
Posts: 92
Joined: Mon Dec 01, 2008 10:05 pm

Post by testone »

It is interesting that the IRS comparison of the filing requirements for Form 8938 and the FBAR (http://www.irs.gov/businesses/article/0 ... 86,00.html) does not mention foreign pensions, such as DPSPs and RPPs. I would think that these types of accounts would need to go on both the 8938 and the FBAR.
nelsona
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Post by nelsona »

Most pensions are not accounts, and the beneficiary has little "signatorY" control over the fund.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing :D
testone
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Post by testone »

No account makes sense, at least for defined benefit plans. Not so sure about defined contribution plans. It is still interesting that the IRS did not list pensions and did not state either way whether required or not for the two forms.
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