"Nearly all bilateral tax treaties contain special rules relating to pension funds or arrangements.... Proposed regulations under Section 897(l) ... define 'pension and retirement benefits' narrowly, but in a way that commentators have criticized as unrealistic.... In the interest of coherence and sound administration, the final regulations should incorporate a presumption that if a pension plan is covered by a treaty, it meets the requirement of Section 897(l)(2)(B)."  MORE >>