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Weil Gotshal & Manges LLP in Tax Management International Journal
Feb. 8, 2022
"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)."
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