Most foreign pension plans are likely characterized as trusts for U.S. tax purposes. Neither the statute nor the regulations define the term “employees’ trust.” However, if a foreign pension (i.e., the trust): (i) was created by a foreign employer, (ii) is administered by the foreign employer, and (iii) is more than half funded by the foreign employer, it seems likely that the foreign pension/trust would be considered an “employees’ trust.” Code §402(b).
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Top 20 Best Foreign Retirement Havens