IRS reissues proposed regs. on deferred compensation plans of foreign corporations or foreign branches of domestic corporations
Article Abstract:
The IRS has reproposed regulations implementing IRC 404A for deferred compensation plans of foreign corporations or foreign branches of domestic firms. The regulations contain the procedures for US companies to follow in figuring out deductions for contributions to deferred compensation plans for the benefit of nonresident aliens. The rules speak to adjustments to profits and earnings for some foreign deferred compensation plans as well as deductions for same.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1993
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Collectively bargained pension plan is a labor organization exempt under Section 501(c)(5)
Article Abstract:
The 2d Circuit held in Morganbesser v US that a pension plan negotiated by collective bargaining was a labor organization according to IRC 501(c)(5) and was therefore not taxable as a nonqualified plan. The pension plan was seeking a refund of taxes paid for a year when the IRS ruled the plan ineligible for the tax exemption under ERISA. The court declined to rule on this issue and instead ruled that the plan was a labor organization.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1993
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Congress revises qualified plan distribution rules. IRS provides guidance on rollover distributions and 20% withholding under 1992 Unemployment Compensation Act
- Abstracts: Congress approves securities law reforms in an effort to streamline regulation, reduce regulatory burdens and promote capital formation for U.S. businesses
- Abstracts: Court review of arbitration. Discipline and decisions: a study of arbitration cases dealing with employee discourtesy
- Abstracts: Recent developments in the arbitration of employment discrimination claims
- Abstracts: PBGC grants small employers temporary relief from reporting missed quarterly contributions for 1997. Taxpayers prevail in small plan audit cases