Do I still need to file Form 8891 for my RRSP?
No. Form 8891 stopped being required for tax years ending after 31 December 2012, and if someone is telling you to file one for an RRSP, they’re working from pre-2014 guidance. What matters far more is what the same relief did not cover. It removed Form 8891, Form 3520 and Form 3520-A for these plans, and it says in terms that it leaves your other reporting obligations alone.
For tax years ending after 31 December 2012 the form is not required, and the reporting still is. Rev. Proc. 2014-55 removed three forms for Canadian retirement plans and expressly preserved everything else, which means Form 8938 and the FBAR still apply on their own terms. People hear “no more 8891” and stop reporting the account entirely.
What did Form 8891 used to do?
It was the RRSP information return, and it carried the treaty election. The IRS released it in 2004 for US citizens and residents holding an interest in an RRSP or RRIF, and it did two jobs at once: it reported distributions, contributions and undistributed earnings, and it was the place you made the Article XVIII(7) election to defer US tax on the plan’s internal growth.
“In 2004, the IRS released Form 8891, U.S. Information Return for Beneficiaries of Certain Canadian Registered Retirement Plans, for U.S. citizens or residents who hold an interest in an RRSP or an RRIF to report distributions received from their RRSP or RRIF, contributions to their RRSP or RRIF, and undistributed earnings” Rev. Proc. 2014-55, section 2.07
That dual role is why the form’s disappearance confuses people. Losing a reporting form and losing an election are very different things, and only one of those happened.
So when did it stop being required?
For tax years ending after 31 December 2012. The revenue procedure both removes the filing requirement going forward and treats eligible individuals as having already made the election, so there’s nothing left to elect on a form.
“is not required to file Form 8891 or a similar statement for taxable years ending after December 31, 2012.” Rev. Proc. 2014-55, section 4.05
The election half is handled separately in section 4.02, which provides that an eligible individual “will not be required to make the election for that first year or for any subsequent years either on Form 8891 or under the procedures set forth in Revenue Procedure 2002-23.” So the deferral is preserved without a form. One thing that is not automatic: revoking a prior election still requires the Commissioner’s consent.
What did the relief NOT cover?
Form 8938 and the FBAR, and the revenue procedure says so directly rather than leaving it to inference. This is the sentence to read twice, because it’s the difference between a simplification and a licence to stop reporting.
“This revenue procedure does not, however, affect any reporting obligations that a beneficiary or annuitant of a Canadian retirement plan may have under section 6038D or under any other provision of U.S. law” Rev. Proc. 2014-55, section 6
Section 6038D is Form 8938. The revenue procedure’s own worked example names the FBAR explicitly too, saying the taxpayer “is not required to report his interest in the RRSP on Form 8891, Form 3520, or Form 3520-A. However, Taxpayer may need to report his interest in the RRSP under section 6038D or under another provision of U.S. law, including the requirement to file FinCEN Form 114.”
| Form | Still required for an RRSP or RRIF? |
|---|---|
| Form 8891 | No, for tax years ending after 31 December 2012 |
| Form 3520 | No, for these plans |
| Form 3520-A | No, and custodians are not required to file it either |
| Form 8938 (section 6038D) | Unaffected by this relief, applies on its own thresholds |
| FinCEN Form 114 (FBAR) | Unaffected by this relief, named in the procedure’s own example |
There’s a historical wrinkle worth knowing if you’re looking at old returns. Under the pre-2014 rules, timely filing Form 8891 could exempt you from section 6038D reporting for that plan, provided you reported the 8891 filing on Form 8938. That interaction is gone along with the form, which is one reason old advice on this reads so differently.
Why does this still come up?
Because the form existed for roughly a decade and a lot of published material predates 2014. If a checklist, a memo or a preparer’s intake asks for Form 8891, that is a reliable sign the source has not been revisited in over a decade, and it’s worth asking what else on it is the same vintage.
- How RRSP and TFSA accounts are treated after a move
- What TFSA reporting actually costs on a US return
- Whether a TFSA is a foreign trust for Form 3520, a different account with a different answer
Worth stating the limit of this page. It settles that Form 8891 is not required and that the relief does not reach section 6038D or the FBAR. It does not work out whether you personally cross the Form 8938 or FBAR thresholds, which depend on your own account values.
What should I do next?
Take Form 8891 off your list and leave the RRSP on it. The deferral is preserved without any filing, so there’s nothing to catch up on for that form. Then check your aggregate foreign account values against the Form 8938 and FBAR thresholds for each open year, since those are the obligations this relief deliberately left standing.
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Yarik Yarosh, CPA. "Do I still need to file Form 8891 for my RRSP?." Blue Cloud CPA, August 7, 2026. https://bluecloudcpa.com/guides/do-i-still-file-form-8891-for-my-rrsp
This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.