Yesterday the IRS published a new practice unit titled “Deferred Compensation Received by Nonresident Alien Individuals.” The practice unit discusses payments to NRAs from four types of deferred compensation plans: Salary deferral – unfunded deferred compensation plans under which U.S. taxation is deferred until payment is made. Distributions from a tax-qualified retirement plan (usually a pension or profit-sharing plan) of a U.S. company. Payments made by a U.S. company under an unfunded “top hat” retirement... Read more →