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Taxation Law Section 

     Our next meeting with be held at 6:00 PM on Thursday, November 6, 2014 in the Bar Association Building of Montgomery County located at 27 West Jefferson Street Rockville, MD 20840.  The meeting will be a round table format discussing options and strategies for tax advisors in navigating offshore compliance issues including an examination of the 2014 Offshore Voluntary Disclosure Program as well as the recently announced streamlined program.  All are welcome.  As always, please feel free to contact us with any questions, suggestions or ideas about future Tax Section programs.

     IRS Provides Relief for Taxpayers with Canadian Retirement Plans.  The IRS announced, in Rev Proc 2014-55, relief procedures for US taxpayers holding investments in certain Canadian retirement plans, including Registered Retirement Savings Plan (RRSP).  Eligible U.S. citizens and residents who are beneficiaries of certain Canadian retirement plans will be treated as having made an election under Article XVIII(7) of the U.S.-Canada Income Tax Treaty, to defer U.S. income tax on income accruing in their retirement plans until a distribution is made, similar to a 401(k) plan under U.S. law.  Absent such election, taxpayers face the prospect of incurring current tax liabilities on contributions to the plan as well as the plan’s earnings. 
Additional Guidance for Applicable Large Employers. IRS issued additional guidance in the form of 25 questions and answers to help with information reporting of health care coverage by large employers under Code Section 6056. The reporting is voluntary for calendar year 2014 and is first required in early 2016 with respect to calendar year 2015. The Q&A can be found on the IRS website at:


John S. Pontius, Jr.
Mark W. Schweighofer


Section Meetings

November 6, 2014
Meeting to be held at 6:00 p.m. in the upstairs conference room of the Bar Association building.


CLE Seminars

None currently scheduled