SECTION 1. PURPOSE a tax-free rollover). Thus, there may be a January 1, 1996, that a…

who is a citizen or resident of either the

mismatch between the timing of the

This revenue procedure provides guid- United States tax and the Canadian tax, United States or Canada and a beneficiary ance for applying Article XVIII(7) of the with the result that the individual may be of a trust, company, organization, or other United States-Canada Income Tax Con- subject to double taxation for which no arrangement that is a resident of the other vention, signed on September 26, 1980, relief is available under Article XXIV of country that is generally exempt from

income taxation in the other country (a

as amended by Protocols signed on June the Convention.

“plan”), and is operated exclusively to

14, 1983, March 28, 1984, March 17, .02 Former Article XXIX(5) . Former

provide pension, retirement, or employee

1995, and July 29, 1997 (the “Conven- Article XXIX(5) of the Convention

benefits, may elect to defer taxation in the

tion”). It supersedes Revenue Procedure addressed the timing mismatch in respect

person’s country of citizenship or resi 89–45 (1989–2 C.B. 596), which pro- of a U.S. citizen who was a resident of

dence, under rules established by the

vided guidance for applying former Canada and a beneficiary of a Canadian

competent authority of that country, with