Understanding Foreign Pensions and Their U.S. Tax Treatment

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Hosted By:
CalCPA
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Location:
2026 CalCPA International Tax Virtual Conference
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Christopher R. Callahan will participate in this session of the 2026 CalCPA International Tax Virtual Conference, which helps professionals identify foreign pensions, understand their structures, and determine how they are taxed in the U.S. The discussion includes PFIC concerns, reporting considerations, and common traps practitioners encounter when advising cross-border clients.

Topics Covered

  • How to identify foreign pensions
  • Type of entity
  • How is it taxed in the US
  • PFIC issues
  • Reporting requirements

Learning Objectives

  • Identify common foreign pension structures and classify them for U.S. tax purposes, including when they may constitute PFICs.
  • Explain U.S. tax treatment of foreign pensions, including income recognition, sourcing, and treaty considerations.
  • Apply reporting requirements—such as Forms 8621, 8938, or FBAR—and recognize frequent pitfalls in cross-border pension planning.

Please note there is a cost to attend.