Article XVIII(7), which was added to the (“RRSP”) by providing that such a U.S.

but not distributed by the plan, until such

Convention by the Protocol that was citizen could elect, under rules estab time as and to the extent that a distribu signed on March 17, 1995, expanded and lished by the competent authority of the

tion is made from the plan or any plan

replaced Article XXIX(5). United States, to defer United States taxa substituted therefor. 2002–15 I.R.B. 744 April 15, 2002

Rev. Proc. 2002–23