International Pension Planning (Portfolio 320)

Bloomberg Tax Portfolio, International Pension Planning, No. 320, is intended to assist the U.S. tax specialist with issues arising from the implementation of pension plans in an international context. “Pension” is intended to encompass a wide variety of deferred compensation arrangements, including qualified pension, profit-sharing, stock bonus and employee stock ownership plans, as well as nonqualified plans, individual deferral arrangements and stock-based executive plans.

The issues addressed are primarily tax, but also covered are ERISA issues. This Portfolio addresses Social Security topics (FICA, taxation and benefits), but local law issues are touched upon only in a cursory fashion, and only as needed to address a point of U.S. tax law or ERISA. Estate tax issues are given only a brief treatment.

The context of the analysis varies. The analysis focuses on the tax effects of plans from the point of view of the employer (primarily deduction issues) as well as the employee (primarily income inclusion issues). Both inbound transactions (U.S. taxation of non-U.S. employers or employees) and outbound transactions (U.S. taxation of U.S. employers or employees working abroad) are considered. A separate section covers deductions for U.S. employers for contributions and accruals to foreign retirement plans (i.e., §404A).

Finally, this Portfolio assumes a basic knowledge of ERISA, qualified plan rules and U.S. taxation of international operations. However, each section contains enough background material to enable subscribers who are unfamiliar with these areas of the law to use the Portfolio.