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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
Tilburg Law Review – Brill
Published: Jan 1, 1998
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