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Posted

I can find references that show US Qualified plans of US Corporations can accrue benefits based on foreign income (for US persons) even if paid in the local currency.

What I have not located are any code sections or regulations addressing this issue. I have spent over two hours on BNA trying to use the search function to find this. Of course, I have trouble with ALL search engines - even GOOGLE!

Does anyone have a clue as to what code section(s) might cover this?

Thanks all.

Posted

From 1.415-2(d)(2): paragraphs (d)(2)(i) and (d)(2)(ii) of this section include foreign earned income (as defined in section 911(b)), whether or not excludable from gross income under section 911. Compensation described in paragraph (d)(2)(i) of this section is to be determined without regard to the exclusions from gross income in sections 931 and 933. Similar principles are to be applied with respect to income subject to sections 931 and 933 in determining compensation described in paragraph (d)(2)(ii) of this section. Hope this helps.

PensionPro, CPC, TGPC

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