I recently stumbled on a reference to the following article, which I am interested to know more about:
- Veena K. Murty, Selected Cross-Border Equity and Deferred Compensation Issues With Funded Foreign Plans, 42 COMP. PLAN. J. 67 (Apr. 4, 2014)
- In addition, the United States applies the limitation separately to general category income and passive category income. I.R.C. § 904(d)(1). See Murthy, Cross-Border, supra note 28, at 9 (suggesting that distributions from a section 402(b) trust, including amounts attributable to earnings in the trust, should be classified as wages, despite the contrary rule applied to earnings of a U.S. tax qualified plan, which are treated as investment income sourced by reference to the situs of the trust).
Reference is made to a "rule" that treats earnings from a U.S. qualified plan as investment income. What "rule" could they be talking about?
Finally, what category does everyone think the pension distributions should go in?