Section 1. General Foreign Trust

Reporting Requirements for Certain Canadian Retirement Plans

Internal Revenue Code section 6048 requires information reporting with respect to certain foreign trusts. Persons subject to these information reporting rules must file Form 3520 ( Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts ) or Form 3520–A ( Annual Information Return of Foreign Trust With a U.S. Owner ), as applicable.

In Notice 2003–25, 2003–18 I.R.B. 855, Treasury and the Internal Revenue Service recognized that some taxpayers with interests in certain Canadian retirement savings plans, as well as the custodians of such plans, were unfamiliar with the requirements for filing Forms 3520 and 3520–A. Accordingly, Notice 2003–25 provides an automatic extension until August 15, 2003, for any person who is required to file a 2002 Form 3520 or Form 3520–A with respect to a Registered Retirement Savings Plan (“RRSP”), Registered Retirement Income Fund (“RRIF”) or other eligible plan within the meaning of section 3 of Revenue Procedure 2002–23, 2002–1 C.B. 744. Notice 2003–25 further provides that Treasury and the IRS are considering establishing for future taxable years a simplified reporting regime for RRSPs and persons with interests in RRSPs and coordinating the reporting requirements with the election described in section 4 of Revenue Procedure 2002–23.