2024-12-06
Yesterday a video was published by Democrats Abroad primarily discussing whether UK Self-Invested Personal Pensions ("SIPPs") need to be reported on Forms 3520 and 3520-A. I am not endorsing Democrats Abroad; I just found the video to be informative, and I thought others might too.
In the video, Rebecca Lammers interviewed tax attorney Stuart Horwich. Stuart not only discusses U.S. tax reporting requirements for SIPPs, but he also comments on the U.S. taxation of lump-sum distributions from U.K. pensions.
Don't be mislead by the title of the video. The title implies that UK SIPPs are not foreign trusts. As Stuart indicates in the video, SIPPs are likely foreign trusts.
Stuart has been active in litigating U.S. international tax rules. Just yesterday, the Court of Federal Claims agreed with Stuart that the Canada-U.S. Income Tax Treaty entitled a U.S. citizen in Canada to claim foreign tax credits against the net investment income tax.
Tags: 402(b) Foreign Pensions, 894 Treaties, Country - UK, Form 3520 / 3520-A, Other - Videos
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
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