Form 8891 with Zero year end balance

[nquery]

Hi,

In 2013, my RRSP account was moved into a new account/number to clean up accounting on my brokers side after I moved stateside in late 2012 (... yes, my canadian broker is licensed to manage both RRSP's and regular accounts for US residents).

As per my searches of this and other forums, I created 2 form 8891's, one for the old account # but with a year end balance of 0 on line 8 and one for the new account #. (I originally elected to defer on my 2012 taxes). In brackets next to the new account # I put "moved from acct 12345". I then E-filed via TaxAct.

However, I realized after the fact that TaxAct was excluding the 8891 with the old account # because the balance was Zero and there were no other distributions/contributions. I went back and forth with them, more out of curiosity's sake than expecting anything to be done, to explain that in this situation it is valid to file a form 8891 with zero's across the board.

The interesting thing is that they said that the E-File data rules won't permit a form 8891 to be filed with 0's in all lines. They then contacted the IRS who told them that this is correct - under this situation I am not a beneficiary of the old account and thus do not file a form 8891. This is what the IRS told TaxAct:

[i]"Under the conditions you describe, it does not appear that the individual is a beneficiary for purposes of Form 8891. Beneficiaries are defined in sections 671-679 of the Code (see IRC 6048(b)(1). Generally, if none of the income derived from the Canadian trust is subject to current taxation in the U.S. or would be subject to taxation absent an election under Article XVIII(7) of the treaty, the individual is not considered a beneficiary and thereby not required to file Form 8891."[/i]

So I find this very strange and not sure what to do. I am not 100% sure that the IRS contact nor TaxAct developers are correct so I am still thinking of just mailing in the missing 8891 with a 1040X. Alternatively, I would have to file a 3520 for the old account # which seems totally ridiculous ...

anyone have any thoughts?

[nelsona]

When one transfers RRSPS, once should file 2 8891's" once for the o;d and one for the new. This is clear since as far as Rev Procs go on this issue.

I would submit both manually.

What IRSA is talking about is the trust aspects of RRSP reporting. This has nothing to do with the deferral aspect, which his the primary reason for 8891.