Part III. Administrative, Procedural, and Miscellaneous

of the Convention because they might not be operated exclusively to provide pension, retirement or employee benefits. It is the position of the Internal Revenue Service that, under current Canadian law, RRSPs and RRIFs are examples of arrangements that meet the conditions stated in the Protocol. Thus, RRSPs and RRIFs qualify for the benefits of Article XVIII of the Convention, and paragraph 2 of Article XXI of the Convention, as amended by Articles 9(1) and 9(3), and Article 10(1) of the Protocol, respectively. The principal author of this notice is Kenneth Allison of the Office of the Associate Chief Counsel (International). For further information regarding this notice contact Mr. Allison at (202)-622-3860 (not a toll-free call).

Weighted Average Interest Rate Update

Notice 96–32

Notice 88–73 provides guidelines for determining the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for the purpose of the full funding limitation of § 412(c)(7) of the Internal Revenue Code as amended by the Omnibus Budget Reconciliation Act of 1987 and as further amended by the Uruguay Round Agreements Act, Pub. L. 103–465 (GATT).

The average yield on the 30-year Treasury Constant Maturities for April 1996 is 6.79 percent. The following rates were determined for the plan years beginning in the month shown below.

RRSPs and RRIFs Under 1995 Protocol to U.S.-Canada Income Tax Treaty

Notice 96–31

This notice clarifies the application of the Convention Between the United States of America and Canada with Respect to Taxes on Income and on Capital, dated September 26, 1980, as amended by the Protocols dated June 14, 1983, March 28, 1984, and March 17, 1995 (the ‘‘Convention’’) to dividends and interest derived by, distributions from, and income accrued in Canadian Registered Retirement Savings Plans (‘‘RRSPs’’) and Registered Retirement Income Funds (‘‘RRIFs’’).