Canadian retirement plan beneficiaries get relief

Under the U.S.-Canada tax convention, beneficiaries in an arrangement exempt from taxation by Canada and operated exclusively to provide pension or employee benefits may defer U.S. recognition of income accrued in the plan but undistributed. A recently issued revenue procedure (Rev. Proc. 2014-55) provides new procedures for making this election, one for beneficiaries who are eligible individuals (as defined in the revenue procedure) and one for beneficiaries who are not eligible individuals.