Orbitax2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)
|Treaty Development|United States-United Kingdom
The Associate Chief Counsel (International) of the US Internal Revenue Service (IRS) has issued a memorandum with an interpretation of Art. 18 (Pensions Schemes) of the 2001 US-UK tax treaty.
The issue presented was whether a US resident could make a tax-deferred rollover distribution from a UK pension scheme to a US retirement plan in circumstances where the dist…
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