Virtual

International Tax Series—Foreign Retirement Plans: Employees' Trusts, Grantor Trusts, or What?

Date: Feb. 27, 2026

Time: 9 – 10 a.m. PT

CPE: 1

Overview

Every month, a new international tax topic. Join the Hodgen Law team live—fresh insights, straight from the source. This month, we’ll explore foreign retirement plans.

Foreign retirement plans can be deceptively complex in the eyes of the IRS. Are they employees’ trusts? Grantor trusts? Nonqualified deferred compensation? U.S. tax treatment depends on form, funding, control, and benefit access, and the stakes are high. This session demystifies how the U.S. classifies foreign retirement structures under income tax and reporting regimes. We’ll explore the nuances of employer-sponsored plans, self-funded pensions, and hybrid structures across jurisdictions. Whether you're advising mobile executives or expats returning to the U.S., this is your map through a global maze.

View all courses in this series.

Formerly named International Tax Lunch Series February 2026

Product Code
1000003994-132942
Credit Type
CPE: 1
CPE-Technical: 1
CTEC-TX: 1
IRS-TX: 1
MCLE LS-TX: 1
Intended Audience
CPAs, tax preparers and advisors who what to stay current on the latest developments on international tax issues.
NASBA Field of Study
Taxes
Level of Difficulty
Overview
Prerequisites
None
Advance Preparation
None

Learning Objectives

Identify the key factors the IRS uses to classify foreign retirement plans and distinguish between employees’ trusts, grantor trusts, and other structures.

Evaluate the U.S. income tax consequences of contributions, growth, and distributions within foreign retirement accounts.

Determine the proper U.S. reporting requirements for a variety of foreign retirement arrangements, including when and how to file FBAR, Form 3520, and Form 8938.

Apply treaty-based planning to reduce the risk of double taxation on foreign retirement distributions.

Advise internationally mobile clients—including inbound U.S. taxpayers and repatriating Americans—on strategies to manage tax exposure across jurisdictions.

Recognize compliance red flags and develop proactive strategies to address IRS scrutiny and avoid penalties.

Major Subjects

Classification of Foreign Retirement Plans Under U.S. Law
Tax Treatment of Contributions and Earnings
Reporting Requirements and Forms
Distribution Rules and Taxation Upon Withdrawal
Planning for Mobile Employees and Returning Expats

Faculty

Philip D.W. Hodgen

Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand....

More about Philip D.W. Hodgen

International Tax Series—Foreign Retirement Plans: Employees' Trusts, Grantor Trusts, or What?

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Overview

Product Code

Credit Type

Intended Audience

NASBA Field of Study

Level of Difficulty

Prerequisites

Advance Preparation

Learning Objectives

Major Subjects

Faculty