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Forum: USA
Mar 27th 2017, 5:32 pm
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

Stop making things even more complicated......:eek:

It's a good question for UK pensions with a US tax free basis....however it's probably not relevant to the OP as they are not a US citizen and...
Forum: USA
Mar 27th 2017, 5:27 pm
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

Periodic distributions are taken over more than a single year. A single payment or one that is made on demand is not a periodic payment.So I don't think that the UK 25% tax free amount is taken in a...
Forum: USA
Mar 27th 2017, 3:23 pm
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

Interpretation is everything......my inclination is that a single 25% cash payment from a UK pension plan, being non-periodic, is more like a lump sum than periodic income and so those that might...
Forum: USA
Mar 27th 2017, 1:02 pm
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

The OP is arguing that because the UK 25% tax free amount does not meet the IRS's definition of a lump sum then it can be treated as pension income and Article 17.1 applies and not Article 17.2....
Forum: USA
Mar 27th 2017, 4:08 am
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

UK pensions paid to US residents are taxable in the US. If you invoke the tax treaty you can avoid paying UK tax on them.

If you had claimed the pension while still a UK resident (ie not a US...
Forum: USA
Mar 26th 2017, 11:05 pm
Replies: 112
Views: 64,236
Posted By nun

Re: UK Pensions related to UK/US Tax Treaty

The critical thing here is whether the UK 25% tax free lump sum is treated as pension income so that it can benefit from the reciprocal tax free status of Article 17.1. Generally, pension income is...
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