Is it an RRP, or an RRSP?



I am a US citizen, and was employed by a Canadian university as a professor 1995-2003. I participated in the pension plan there until my return to the US in 2003. When I terminated my employment in Canada, my pension was rolled over into an individual plan (Sun Life's Group Choices Plan), and I ceased contributing to it. It has gone up about 60% in value since then due to investment performance. I will retire in the US. My assumption was that this was like my current US university retirement plan (a 401A plan)and that I would pay US and/or Canadian taxes on it when I started recieving payments about 20 years from now. But, I recently noted that Sun Life calls my current current Canadian account an RRSP, and I am concerned whether I should have been reporting to the IRS in the US on it. Am I in trouble?

david ingram replies:

I hate to say it but if you have not been reporting it of forms 8891 and T DF 90-22.1, you are potentially liable for arbitrary fines of up to $500,000 plus 5 years in jail plus 35% of the value of the RRSP plus 5% for each year the RRSP has not been reported. See the bottom two questions on Schedule B - substitute the much more friendly form 8891 for the 3520 mentioned in the bottom question. You can print out and read the details of both forms by going to and clicking on forms and publications.

In Canada, it is common to roll an employer Pension plan into a RRSP (usually a locked in plan).

In the USA, it is common to roll an employer 401(K) plans into an IRA.

You have an RRSP and must file an 8891 form each year and assuming it
and any other Canadian accounts you have exceeded $10,000 US, you were required to file form(s) T D F 90-22.1 as well. See those bottom two questions on schedule B again.


Although i have seen and know of many people fined under the T D F 90-22.1 (over 1,000 clients of one tax consultant named Jerome Schneider as one example) no one has been fined yet that I know of for the 8891 forms.

AND, I have never seen anyone fined who came forward and started filing with the current year. Fill out the 8891 and send it in with a 1040X if you have already filed.

Fill in the TDF 90-22.1 and mail to Detroit.