SECTION 2. BACKGROUND

tion with respect to any income accrued in the RRSP but not distributed by the RRSP, until such time as a distribution was made from such RRSP or any plan substituted therefor. The rules for making an election under former Article XXIX(5) were set forth in Revenue Procedure 89–45. Additional guidance was set forth in Revenue Ruling 89–95 (1989–2 C.B. 131), which provided that if the proceeds of a RRSP were rolled over to a Canadian registered retirement income fund (“RRIF”), the RRIF would be treated as a plan substituted for the RRSP, with the result that both the proceeds that were rolled over from the RRSP and the income subsequently accrued in the RRIF could qualify for deferral under former Article XXIX(5).

26 CFR 601.602: Tax forms and instructions. (Also Part I, section 894; Part II, United States- Canada Income Tax Convention.)

Canadian income taxation until it is actu- .03 Article XVIII(7) . Article XVIII(7)

Rev. Proc. 2002–23 ally distributed from the plan (or from of the Convention now provides, effective

for taxable years beginning on or after

another plan to which it is transferred in