Withholding tax on retirement plan distributions to employees working in Puerto Rico

Article Abstract:

Determining taxation of qualified benefit plan distributions to employees in Puerto Rico requires plan administrators to consider Puerto Rican citizenship and residency rules as well as segregating plan contributions and earnings. Puerto Rican source income is exempt from US income tax when the taxpayer has been a resident of Puerto Rico for the whole tax year. Contributions to plans can be treated as Puerto Rican source income, but the IRS has ruled that the plans earnings are considered US source income.

International aspects, Distribution, Income tax, Qualified benefit plans, Withholding tax

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Martin v. Comm'r and the doctrine of constructive receipt

Article Abstract:

In Martin v. Commissioner the US Tax Court held that employees are not in constructive receipt of income under a deferred compensation plan in which employees could change the form of the payment when it began. The IRS argued that George C. Martin and Richard T. Bick were in constructive receipt when they left their employer. However, the court found that the deferred compensation plan did not satisfy the criteria that would have placed Martin and Bick in constructive receipt.

Cases, Employee benefits, Deferred compensation

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Final Regulations under Section 512 - swap income and tax-qualified pension plans

Article Abstract:

The IRS on Jul 29, 1992 issued its Final Regulations for IRC Section 512(b), declaring that income generated by swap agreements would not be classified as unrelated business taxable income (UBTI). Consequently, many tax-qualified pension plans and other tax-exempt organizations can be expected to seek out swap agreements and other notional principal contracts. The Final Regulations exempt pension plans from UBTI regardless of the reasons for joining a swap agreement.

Taxation, Pension funds, Unrelated business income tax, Swaps (Finance)

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