Pension trusts
(c) Pension trusts(1) In general. A controlled entity includes a separately organized pension trust if it meets the following requirements: (i) The trust is established exclusively for the benefit of (A) employees or former employees of a foreign government or (B) employees or former employees of a foreign government and non-governmental employees or former employees that perform or performed governmental or social services; (ii) The funds that comprise the trust are managed by trustees who are employees of, or persons appointed by, the foreign government; (iii) The trust forming a part of the pension plan provides for retirement, disability, or death benefits in consideration for prior services rendered; and (iv) Income of the trust satisfies the obligations of the foreign government to participants under the plan, rather than inuring to the benefit of a private person. (2) Illustrations. The following examples illustrate the application of paragraph (c)(1).