“Effective for taxable years beginning after December 31, 1973, if—“(1) an employer is engaged in a trade or business in a foreign country,
“(2) such employer is required by the laws of that country to make payments, based on periods of service, to its employees or their beneficiaries after the employees’ retirement, death, or other separation from the service, and
“(3) such employer establishes a trust (whether organized within or outside the United States) for the purpose of funding the payments required by such law,
then, in determining for purposes of paragraph (5) of section 404(a) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] the taxable year in which any contribution to or under the plan is includible in the gross income of the nonresident alien employees of such employer, such paragraph (5) shall be treated as not requiring that separate accounts be maintained for such nonresident alien employees.”
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