Some of you are familiar with attorney Hale Sheppard who has written extensively on FBAR issues.  Renounceuscitizenship has provided links to his past writing at Looking for Mr. FBAR – In Search of FBAR fullfilment and Consciousness, which is an excellent post that provides history and back ground for the FBAR.  In his post, he refers to Hale Sheppard as the FBAR Scholar for his 2006 work EVOLUTION OF THE FBAR: WHERE WE WERE, WHERE WE ARE, AND WHY IT MATTERS   If you are still somewhat hazy on this history, and especially if you are going through the OVDI, this is required reading.

I bring this up as an introduction to Hale, as I recently came across some of his writing from 2008 about the Canadian RRSP.

Not being a Canadian, the article didn’t resonate with me, in the past, as something I would be interested in. Up until late 2009, I personally had never heard about the RRSP.  But since having the pleasure of experiencing OVDP “slime line” Minnow processing plant, and hearing from Canadians here and on Jack’s blog about their struggles with how the IRS is looking at their retirement plans, I was drawn to this article.

Hale follows the evolving tax treatment of Canadian RRSPs and RRIFs, identifies the relevant U.S. tax requirements and the penalties for non-compliance, illustrates the problem by describing a typical scenario, and explores two major solutions, focusing on the pros and cons of each.  The article was published in the International Tax Journal. The title of this work is, When bygones aren’t bygones, exploring tax solutions for US persons with undeclared Canadian retirement plans and accounts.