Cross-Border Planning for Retirement Plans
100 Terranea Way, Rancho Palos Verdes, CA
Substantial wealth can accumulate in pension funds and other retirement plans. In the domestic context, complex rules often complicate, if not frustrate, planning to obtain tax efficiencies and to minimize the tax hit when funds are distributed to plan participants. These tasks become only more complex in the international context, for example, where a participant earns a retirement benefit in one country and changes his or her residency to another country before receiving distributions of their accrued retired benefits. This panel of two U.S. attorneys will address these questions from the perspective of required multi-jurisdictional tax reporting and compliance and creative tax planning for the initial participation in, and the receipt of benefits from retirement plans in a variety of contexts. They will consider the U.S. and foreign tax treatment of non-U.S. retirement benefits (e.g., under Canadian and Australian plans) held by U.S. citizens and residents, as well as the special tax treaty rules that may impact the taxation of such foreign retirement benefits or the receipt of U.S. retirement benefits by U.S. nonresident aliens residing in countries with favorable tax treaties.

