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Forum: USA
Mar 5th 2018, 9:59 pm
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

These are all pension oncome, so Lines 16a and 16b on the 1040 and foreign source these on a general basket Form 1116.
Forum: USA
Dec 28th 2017, 1:37 pm
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

One assumes you have already been reporting the personal pension each year on the Form 8938 & the FBAR. These are unavoidable.


If you argue that the pension commencement lump sum is US tax free...
Forum: USA
Oct 8th 2017, 8:18 am
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

Most folks (including HMRC) argue that a "lump-sum" means a complete distribution. As this has never been tested in court, no-one knows what "lump-sum" is supposed to mean.
Forum: USA
Aug 11th 2017, 5:13 am
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

Small question first...how have you been describing the Teachers' Pension Plan on your annual Forms 8938?
Forum: USA
Mar 27th 2017, 4:22 pm
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

Under US domestic law an LSD is a complete distribution. Anything else is arguably periodic. I think this is the argument.


Now that we have flexi-access drawdown and UFLPS to think about as...
Forum: USA
Mar 27th 2017, 12:21 pm
Replies: 112
Views: 64,220
Posted By Cook_County

Re: UK Pensions related to UK/US Tax Treaty

The technical explanation is the view of the US Treasury. It is not HMRCs interpretation.


I think in any case because of law changes in 2015 in the UK you might want to ask the attorney if he...
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