IRAConfusion

I have a question around this comment from HMRC Admin 19, "From the UK's perspective, an IRA in not a pension and so, it is not taxed as a pension, irrespective of its status in the USA. It is treated as a savings account and taxed in the UK, under the rules for interest. It is not covered by the tax treaty on pensions, but that of interest. Regular payments and lump sums are taxable as interest.." I understand that the IRA is not considered a pension by HMRC because it is not a UK pension. However, I'm confused that you say that it is not covered by the pension article of the tax treaty. I've been looking into this. Article 3o of the treaty defines pensions. The exchange of notes then specifically says that "individual retirement accounts" are understood to be pension schemes for the purposes of the treaty. So, irrespective of how HMRC views IRAs domestically, the treaty says that they are pensions and so Article 17 would apply to determine the tax position? Overall, I don't think that whether the distribution is taxed as interest or pension particularly matters unless there is a savings tax-free allowance to be used, or unless an inherited IRA is involved. If HMRC's argument is that an IRA is not a pension and they ignore the treaty, then if a person were to receive a lump sum from a deceased person's IRA then this would not be taxable in the UK? Because it is a distribution of "something" from an estate?