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Posted Mon, 24 Jul 2023 09:22:45 GMT by
I am a UK ordinary citizen and resident but also have a "Traditional IRA" pension account in the USA from 1990s when I used to work there. Last year I have converted a (lump sum) part of this American IRA account into a Roth IRA and paid US tax on this conversion. None of the funds have left the IRA wrappers, this was a conversion from one USA pension vehicle (Traditional IRA) to another (Roth IRA). Under US-UK tax treaty (article 17 paragraph 2) such transaction is not subject to UK tax. The question is whether I am required to report it on my UK self-assessment and if so, how. Many thanks
Posted Tue, 01 Aug 2023 13:20:06 GMT by HMRC Admin 32
Hi,

As its a conversion and not a withdrawal of the actual pension, this is not taxable in the UK and doesnt need to be reported here.

Thank you.
Posted Mon, 25 Mar 2024 15:08:54 GMT by sjayawant
I am a US citizen, US domiciled, and a UK resident. I have a US "Traditional IRA" and a "Roth IRA". I plan to make multiple and irregular (non-periodic) direct conversions from the Traditional IRA to the Roth IRA. No money will be distributed out of the pension sphere. In other words, several conversions over several years will be directly transferred from one USA pension (Traditional IRA) to the other (Roth IRA). US tax will be paid on each conversion. Under US-UK tax treaty (article 17 paragraph 2) such transactions are not subject to UK tax. The question is whether I am required to report any of these conversions on my UK self-assessment? Thank you.
Posted Mon, 25 Mar 2024 16:30:58 GMT by sjayawant
One more thing...it appears that whether periodic or lump sum conversions, neither should be UK taxable events because of Tax Treaty Article 18(1) excludes UK taxation of a US IRA to Roth IRA because it is a transfer between pension schemes and not a distribution to the individual. Would you please confirm that the amount, frequency and regularity of direct US IRA to US Roth IRA conversions are irrelevant based on the conditions I've outlined? Thank you.
Posted Wed, 27 Mar 2024 14:00:45 GMT by HMRC Admin 5
Hi sjayawant

HMRC cannot comment on future events as legislation and/or plans may change.

Thank you

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