Pension funds
(5) Pension funds(i) Pension fund defined. The term pension fund shall mean a government pension fund or a nongovernment pension fund, as those terms are defined, respectively, in paragraphs (b)(5)(ii) and (iii) of this section, that is a trust, fund, foundation, or other entity that is established exclusively for the benefit of employees or former employees of one or more employers, the principal purpose of which is to provide retirement, disability, and death benefits to beneficiaries of such entity and persons designated by such beneficiaries in consideration for prior services rendered. (ii) Government pension funds. A government pension fund is a pension fund that is a controlled entity of a foreign sovereign within the principles of 1.892-2T(c)(1) (relating to pension funds established for the benefit of employees or former employees of a foreign government). (iii) Nongovernment pension funds. A nongovernment pension fund is a pension fund that (A) Is administered in a foreign country and is subject to supervision or regulation by a governmental authority (or other authority delegated to perform such supervision or regulation by a governmental authority) in such country; (B) Is generally exempt from income taxation in its country of administration; (C) Has 100 or more beneficiaries; and (D) The trustees, directors or other administrators of which pension fund provide the documentation required in paragraph (d) of this section. (iv) Beneficiary of a pension fund. The term beneficiary of a pension fund shall mean any person who has made contributions to a pension fund, as that term is defined in paragraph (b)(5)(i) of this section, or on whose behalf contributions have been made, and who is currently receiving retirement, disability, or death benefits from the pension fund or can reasonably be expected to receive such benefits in the future, whether or not the person's right to receive benefits from the fund has vested. See paragraph (c)(7) of this section for rules regarding the computation of stock ownership through nongovernment pension funds.