QUESTION:
My client is dual citizen, U.S./Canada. He lived and worked in Canada for 15
years and contributed to RRSP. He returned to the U.S. in 1992 and has been
reporting correctly to defer the U.S. tax on the RRSP income. Does he have
basis in the U.S. to the extent of his contributions plus interest,
dividends and realized gains in 1992? Is the U.S. citizen returning to the
U.S. treated differently from a Canadian citizen who becomes a U.S. resident
with an RRSP?
I have some complicated retirement issues and may need your tax prep
services. Thank you in advance.
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david ingram replies:
Up until noon yesterday, I would have automatically said that your client
has a basis for the value of the RRSP when he returned across the border for
his contributions at least.
But apparently there is a KPMG release which I have not seen that suggests
that such is not the case because of a US change in Oct or Nov 2004.
This will be the subject of a little research project that Gary Gauvin and I
intend to follow up with after the Oct 15th second or third deferral
deadline.
I will pass this along to the list and If anyone has a definitive answer,
please pass it along.
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