US 401k and IRA plans have been ruled "not" foreign super, because they are accessible before retirement and so are not strictly a retirement plan. What about an Employee Stock Ownership Plan (ESOP) which has stricter rules? 25% of the ESOP funds can be accessed at age 55 (if the employee has worked for the company at least 10 year), and another 25% at age 61. The remaining 50% cannot be accessed until the employee leaves the company. Are there any relevant rulings on this?