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3 Comments

  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
    Doug

  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.

    Phil.

  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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