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  • RE: US pension and UK Tax

    A separate issue I have is receiving both US Social Security and UK state pension. I am US citizen and UK Permanent resident. Article 17(1)(b) Tax agreement between US and UK states "Distributions in one country are exempt from taxation in another. The country of residence at time of distribution has sole right to tax the distribution." I therefore include my SS pension on my UK tax return. It gets slightly complicated on US tax return and I will get back to the forum on whether and how I include my US and UK pensions on my f1040 tax return. Passive and Earned Foreign income is reported on f1116 and tax credits are determined whilst allocating standard deduction between incomes. However, the instructions for f1116 do not require the form for any income that is re-sourced due to taxation treaties. Furthermore f8833 also is waived on the instructions for where "a treaty reduces or modified the taxation of income derived by an individual from dependent personal services, PENSIONS, annuities, social security, and other public pensions, as well as income derived by artists..." SO...I am waiting to speak with US IRS about my UK and US pensions and hopefully both can be exempt on the front page of f1040 and no need for tax credits etc. it is interesting how different the tax rates are between the two countries (US lower) but standard deduction is much higher in UK. I'm trying not to be forced into f1116 as the tax credit limited to US tax rates which for me are lower. I think the whole US/UK tax scenario is a nightmare because ultimately Article 1(4) reserves the right to tax it's citizens as if the convention had not come into effect and for long-term residents in UK if you are deemed to have left the US, you can lose US citizenship for tax purposes and all assets revalued and taxed. Also I will need to fill out Alternative Minimum Tax form in US. My hair is thinning.