1. 1

    Dan Dane

    Although the article is correct as far as it goes it is potentially misleading as it misses the point that a transfer from a UK pension to another jurisdiction is considered by the IRS a taxable distribution. I have a letter to this effect from the IRS and this concurs with the view of a leading International accountancy firm. So if you don`t mind suffering tax at the point of transfer to Malta-no problem for Brits. If you have a tax credit then this can be used to offset any distribution tax but this is only likely to be the case of US persons who have worked and paid UK taxes.

  2. 2

    James M

    I too have see the IRS letter. Which indeed does state that a transfer of a UK pension to a third state pension scheme would not be covered by the UK/USA DTA.

    However I have also see US legal council confirmation that the IRS will accept a QROPS transfer, without creating a tax event. As a QROPS is a UK Qualifying Pension sanctioned by and only existing with consent of HMRC.

    So a QROPS is a UK pension but held overseas.


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