The IRS issues Revenue Ruling 2008-40 dealing with the treatment of amounts transferred from a qualified trust to a nonqualified foreign trust.
Excerpt from Document
Whether a transfer of amounts from a trust under a plan qualified under Section 401(a) of the Internal Revenue Code to a nonqualified foreign trust is treated as a distribution.
Whether this result is different if the transferee plan satisfies the requirements of Section 1165(a) of the Puerto Rico Internal Revenue Code and is described in section 1022(i)(1) of the Employee Retirement Income Security Act of 1974.
Link http://www.irs.gov/pub/irs-drop/rr-08-40.pdf
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