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.

Laws, regulations and rules, Tax deductions

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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.

Cases, Labor unions, Tax exemption, Tax exemptions

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