Entries by Manager

IRS Reorganizes Transfer Pricing Compliance Programs and International Coordination

On July 27, 2011, the IRS announced that it is taking additional steps in its continuing efforts to improve the agency’s international operations. First, the IRS Advance Pricing Agreement (APA) Program, concerned exclusively with reaching pre-filing agreements with taxpayers on transfer pricing, will shift from the office of IRS Chief Counsel to an office under […]

Reporting Canadian RRSPs and RRIFs in the United States: Form 8891

It comes as a surprise to most taxpayers the Canadian Registered Retirements Savings Plans (RRSPs) and Registered Retirement Income Funds (RRIFs) must be reported in the United States.  Yet, any U.S. citizen or resident who is a beneficiary of an RRSP or RRIF must complete Form 8891 and attach it to Form 1040. A U.S. […]