Section 2. Relief from 2002 Foreign

Trust Reporting Requirements for Certain Canadian Retirement Plans

Treasury and the IRS are continuing to work toward implementation of an alternative, simplified reporting regime for Canadian retirement plans for future taxable years. Treasury and the IRS have concluded, however, that additional relief with respect to 2002 Form 3520 and Form 3520–A reporting requirements should be provided to RRSPs and RRIFs and their beneficiaries.

First, with respect to the 2002 taxable year, if the beneficiary of an RRSP or RRIF (a) makes or has made an election with respect to the plan in accordance with section 4 of Revenue Procedure 2002–23 or section 3 of this notice, (b) complies or has complied with the annual reporting requirements of Revenue Procedure 2002–23 for the taxable year, and (c) received no distributions from the plan during his or her 2002 taxable year, then no Form 3520 or Form 3520–A with respect to the plan is required.

Second, an individual, RRSP or RRIF that has filed or files a Form 3520 or Form 3520–A for the 2002 taxable year that does not provide all appropriate information may be requested by the IRS to provide such information. Unless the IRS requests such information and the individual or plan fails to provide the IRS with the information identified in such request, no individual or plan that has filed or files a Form 3520 or Form 3520–A with respect to the 2002 taxable year will be subject to failure to file penalties. The individual or plan should write the following on the top of the first page of the Form 3520 or Form 3520–A: “CANADIAN RRSP” OR “CANADIAN RRIF” as the case may be.