rocknrolls2 Posted February 11, 2007 Share Posted February 11, 2007 Company x is headquartered in the United States and has a Canadian branch. The branch maintains a "retirement contribution arrangement" ("RCA") which is essentially a non-qualified plan where the employer gets much of the benefits of a qualified plan, by being able to make a current deduction for contributions to the RCA, the participating employees are only taxed at the time they receive a distribution and while, in the RCA, the assets are protected from the employer's creditors. In addition, the assets are held by either a custodian or trustee. Assuming that the 90% resident test is satisfied, can a US employer elect to deduct contributions pursuant to Code Section 404A? Link to comment Share on other sites More sharing options...
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