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Forum: USA

Aug 11th 2017, 2:32 pm

Replies: 112

Views: 64,244

Posted By Dominic0012

Re: UK Pensions related to UK/US Tax Treaty

The main area which I do not think has been covered is residence and what actually constitutes a state to have taxing rights under the treaty in art 4

So the specific matter which i think is...

Forum: USA

Aug 10th 2017, 9:51 pm

Replies: 112

Views: 64,244

Posted By Dominic0012

Re: UK Pensions related to UK/US Tax Treaty

I would like to resurface this debate.

The consensus is that the savings clause applied and art 1(4) makes the PCLS taxable.

I would like the debate to shift to who exactly falls under art 1(4)...

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