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ERISA, FOREIGN RELATED EMPLOYEE BENEFIT PLANS, & U.S. BUSINESS: INTERNATIONAL TAX ASPECTS AND IMPLICATIONS

ERISA, FOREIGN RELATED EMPLOYEE BENEFIT PLANS, & U.S. BUSINESS: INTERNATIONAL TAX ASPECTS AND... Luis D e n a Osollo* * Luis Dena Osollo, J.D., The University o f Santa Clara., LL.M.(Taxation), Golden Gate University. The author would like to honour the memory o f Mr. And Mrs. Joseph M. And Alisa L. Warren, and to also express thanks to Prof. Philip J. Jiminez, Prof. Mark Boxer and Prof. Michael Hardgrove. E R I S A , F O R E I G N R E L A T E D E M P L O Y E E B E N E - FIT PLANS, � U . S . BUSINESS: INTERNATIONAL T A X A S P E C T S AND IMPLICATIONS INTRODUCTION T h e following discussion tracks the operation of the Internal Revenue Code provisions regarding the tax consequences of indirect compensation to a US citizen, resident, or a nonresident alien paid through a qualified retirement plan and the tax consequences of contributions by an American Employer.' Although the ERISA' law distinguishes between certain pension benefit plans and welfare benefit plans3, it is the former that either provides retirement income or provides for the deferral of income until the termina- tion o f employment and whose extra-territorial http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png Tilburg Law Review Brill

ERISA, FOREIGN RELATED EMPLOYEE BENEFIT PLANS, & U.S. BUSINESS: INTERNATIONAL TAX ASPECTS AND IMPLICATIONS

Tilburg Law Review , Volume 7 (3): 221 – Jan 1, 1998

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Publisher
Brill
Copyright
© 1998 Koninklijke Brill NV, Leiden, The Netherlands
ISSN
2211-0046
eISSN
2211-2596
DOI
10.1163/221125998X00164
Publisher site
See Article on Publisher Site

Abstract

Luis D e n a Osollo* * Luis Dena Osollo, J.D., The University o f Santa Clara., LL.M.(Taxation), Golden Gate University. The author would like to honour the memory o f Mr. And Mrs. Joseph M. And Alisa L. Warren, and to also express thanks to Prof. Philip J. Jiminez, Prof. Mark Boxer and Prof. Michael Hardgrove. E R I S A , F O R E I G N R E L A T E D E M P L O Y E E B E N E - FIT PLANS, � U . S . BUSINESS: INTERNATIONAL T A X A S P E C T S AND IMPLICATIONS INTRODUCTION T h e following discussion tracks the operation of the Internal Revenue Code provisions regarding the tax consequences of indirect compensation to a US citizen, resident, or a nonresident alien paid through a qualified retirement plan and the tax consequences of contributions by an American Employer.' Although the ERISA' law distinguishes between certain pension benefit plans and welfare benefit plans3, it is the former that either provides retirement income or provides for the deferral of income until the termina- tion o f employment and whose extra-territorial

Journal

Tilburg Law ReviewBrill

Published: Jan 1, 1998

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