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  International tax & business 2016

The United States income tax treatment of Australian superannuation funds owned by US Persons

Source: National

Published Date: 25 Aug 2016

 

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This paper covers:

  • current law and reason for suggested changes
  • superannuation guarantee scheme should be classified as a social security tax for U.S. tax purposes
  • treasury regulations promulgated under Sections 402 and 83 should be clarified to exempt the Australian superannuation funds
  • since Australian superannuation funds are the equivalent to a social security program they should not be analyzed as foreign employee trusts under U.S. tax law
  • several areas of U.S. tax law already exempt social insurance programs of foreign governments from tax and reporting obligations.
Author(s)

Individual Session

The United States income tax treatment of Australian superannuation funds owned by US Persons

Author(s): Marsha Dungog , Roy Berg
Materials from this session:

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Details

  • Published By: Roy Berg, Marsha Dungog
  • Published On:25 Aug 2016
  • Took place at:Crown Conference Centre, Melbourne

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