Transfer of U.K. Benefits to US Plan Not Eligible for Rollover

 A Memorandum from the Associate Chief Counsel explains that parenthetical language in Article 18 of the U.S.-U.K. income tax treaty can not be interpreted to allow a tax-deferred rollover of benefits from a U.K. pension plan to a U.S. retirement plan if the benefit otherwise does not satisfy the requirements to constitute an “eligible rollover distribution” within the meaning of Section 402(c)(4). 

Document Excerpt

This memorandum addresses the possible application of Article 18 (Pension Schemes) of the U.S-U.K. income tax treaty to a rollover distribution from a U.K. pension scheme to a U.S. retirement plan. This document may not be used or cited as precedent.

Link http://www.irs.gov/pub/irs-utl/am2008009.pdf

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