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RE: IRA tax treatment
Dear HMRC, I have some questions related to the above regarding IRAs. There are several kinds of IRAs: Traditional IRA, Roth IRA, Simplified Employer Pension (SEP) IRA, SIMPLE IRA, as well as inherited versions of Traditional and Roth which have been mentioned. Where HMRC Admin 19 says "From the UK's perspective, an IRA in not a pension" I think "IRA" refers to "Traditional (Inherited)" IRA, as other questions/answers mention that Roth IRAs are different. I understand the answers given above to mean that Traditional IRAs do not "generally correspond" to a UK workplace pension scheme, but contributions may be tax-deferred (if the account was opened before beginning work in the UK), growth within the account is not taxed, but withdrawals are taxed as savings interest. Is that correct? Roth IRAs differ in that contributions are post-tax and withdrawals are tax-free in the US. Are Roth IRAs considered to "generally correspond" to a UK pension scheme in any sense? I understood the treaty position on these to be that they do not correspond, but contributions are post-tax and growth and withdrawals are untaxed in both US and UK regimes. (thus making them, in UK terms, more like an ISA though with restrictions on withdrawals). Is that correct? Finally, SEP IRAs and SIMPLE IRAs are Traditional IRAs that employers (including self-employed individuals who might be working outside the US) can also contribute pre-tax income to (which is a deductible business expense for the employer). They are similar in some respects to SIPPs, employees can contribute up to the fairly low annual Traditional IRA limit but employers can contribute up to higher limits (something like the lesser of 25% of employee pay or $67k for SEP IRAs) making them potentially more attractive for the self-employed given that there are tax reporting complications for US tax residents having SIPPs. Are SEP IRAs or SIMPLE IRAs considered to "generally correspond" to any UK pension scheme (e.g. SIPPs or SSAS)? And if so would employee or employer contributions to them be tax-deferred / deductible as business expenses for UK tax purposes? Does this depend on whether the employer is UK tax resident (e.g. a self-employed individual paying employer contributions)? I asume that the answers regarding non-taxation of growth and taxation of withdrawals are the same as for Traditional IRA. I have looked and not seen anything specific about SEP IRAs or SIMPLE IRAs on this forum. They are specifically listed (as "individual retirement plans that are part of a simplified employee pension plan that satisfies section 408(k), individual retirement accounts, individual retirement annuities, section 408(p) accounts, and Roth IRAs under section 408A" in the "exchange of notes" as of July 2001 appended to the treaty. Specifically SEP IRAs are section 408(k) and SIMPLE IRAs are section 408(p). Thanks in advance