Page 59 - International Taxation IRS Training Guides

Cross-Border
Pension Plans (Cont’d)

provision,
 In the absence of an applicable treaty

and earnings of a foreign pension plan
contributions
for the benefit of
a U.S. citizen or resident employee

are generally
taxed much like the contributions and
earnings of a domestic
non-qualified plan.

plan contributions are non-deductible for U.S.
• Employee
income
tax purposes;

may be taxed currently on employer plan
• The employee
contributions;
and
• Plan participants
are taxable currently on plan earnings.

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