Foreign Corporations Retirement Plan

[Guest Ed F.]

A U.S. citizen non-resident plans to establish a Seychelles Island corporation. He will be the sole owner and employee of the corporation. The corporation will contract with a U.S. corporation to provide consulting services to various entities in Asia and Europe. The U.S. citizen only travels to the U.S. once a year. Can the Seychelles Island corporation establish a defined benefit plan for its sole owner-employee which will be qualified under Section 401(a), provided that the trust established is a U.S. trust?