id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-464	Blum, Cynthia	U.S. Income Taxation of Cross-Border Pensions	2022	108	.pdf	application/pdf	54931	2834	59	56-446, 1956-2 C.B. 1065, 1066 (lump sum distribution from U.S. qualified pension plan to Canadian resident, paid on death or other separation from service, treated as capital gain under § 402(a)(2), was exempt from U.S. tax under article VI A of U.S.-Canada Income Tax Convention, as a pension, or under article VIII, as a capital gain), modified by Rev. Rul. This change would greatly simplify U.S. source- based taxation of distributions from U.S. qualified pension plans (when there is no treaty bar to taxation); with this change, it would no longer be necessary to separately identify the accretions element of a distribution or to determine whether the requirements of section 871 (f) are met.	cache/ftr-464.pdf	txt/ftr-464.txt