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  1. Would ownership of a defined contribution pension plan established in the UK (i.e., employee contributions combined with employer contributions, but no defined benefit) be considered a foreign trust and require completion form 3520?
    Many thanks

  2. @Shailen,

    If you have a foreign defined benefit pension plan, you have to start from the operating assumption that it is a foreign trust (with all of the gruesome tax results) unless you can find a way out via an income tax treaty.


  3. Thank you for organizing the webinar – this is the second one I attended, and they are truely helpful. I am neither an accountant nor lawyer, but find these helpful and done in a manner that I am able to follow.

    I had a quick question following today’s webinar, and would really appreciate your comment – do the foreign defined benefit pension plans (where pension is based on years of service and income and funded by employer) have any trust implications ?

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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.