This revenue procedure provides that eligible U.S. citizens and residents with certain Canadian retirement plans will be treated as making an election under paragraph 7 of Article XVIII 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. Such individuals will be treated as having made the election in the first year in which they would have been entitled to make the election under the treaty. This revenue procedure also eliminates a reporting requirement associated with such Canadian retirement plans.

This notice amplifies Notice 2010–62; 2010–40 I.R.B. 411, by providing additional guidance regarding the codification of the economic substance doctrine and the related penalty amendments.

Notice 2014–59 announces the intention of the Department of the Treasury (Treasury) and the IRS to amend certain provisions of the temporary regulations published under sections 1441, 1442, and 6049 of the Internal Revenue Code (Code) on March 6, 2014, to provide modified applicability dates with respect to: (i) the standards of knowledge applicable to a withholding certificate or documentary evidence to document a payee that is an entity under § 1.1441–7(b); and (ii) the rules under § 1.6049–5(c) providing the circumstances under which a withholding agent or payor may rely on documentary evidence provided by a payee instead of a withholding certificate to document the foreign status of the payee for purposes of chapters 3 and 61. Prior to the issuance of these amendments, taxpayers may rely on this notice regarding the modified applicability dates.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for September 2014 used under § 417(e)(3)(D), the 24-month average segment rates applicable for October 2014, and the 30-year Treasury rates. These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA).

This revenue procedure provides that eligible U.S. citizens and residents with certain Canadian retirement plans will be treated as making an election under paragraph 7 of Article XVIII 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. Such individuals will be treated as having made the election in the first year in which they would have been entitled to make the election under the treaty. This revenue procedure also eliminates a reporting requirement associated with such Canadian retirement plans.

This revenue procedure provides that eligible U.S. citizens and residents with certain Canadian retirement plans will be treated as making an election under paragraph 7 of Article XVIII 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. Such individuals will be treated as having made the election in the first year in which they would have been entitled to make the election under the treaty. This revenue procedure also eliminates a reporting requirement associated with such Canadian retirement plans.