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UK-Based Retirement Accounts for U.S. Taxpayers: Mastering Reporting, Maximizing Planning Opportunities

Utilizing Treaty Provisions to Achieve Optimal Tax Results While Complying With Foreign Reporting Requirements

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, February 21, 2023

Recorded event now available

or call 1-800-926-7926

This course will provide tax advisers with a deep dive into tax reporting requirements and planning opportunities for clients who take distributions from, or have ownership of, UK-based retirement accounts such as self-invested personal pensions (SIPPs) and other plans. The panel will discuss the U.S. tax law and treaty provisions that exempt SIPPs from the ordinary treatment as a non-qualified plan, detail events that trigger U.S. recognition, and outline tax planning and reporting guidance on distributions from SIPPs.


Foreign retirement plans and pensions present tax reporting and planning challenges for U.S. taxpayers. In many instances, these accounts, while generally receiving deferral treatment on contributed amounts in their host countries, do not qualify for beneficial U.S. tax treatment because they do not meet U.S. requirements of "qualified plans." However, U.S. taxpayers owning and/or receiving distributions from UK retirement plans have unique planning opportunities.

For U.S. tax purposes, UK-based retirement plans are treated differently from "funded plans" in other countries due to treaty provisions between the U.S. and Great Britain. The U.S. tax convention with the UK uniquely contains comprehensive guidance on pensions, providing rules governing contributions, earnings, and distributions. Tax advisers serving clients with UK-based retirement plans must understand the rules to avoid incorrect or incomplete reporting.

UK-based retirement accounts owned by U.S. taxpayers require extra tax reporting requirements, with significant penalties for failure to comply. Tax advisers must be aware of all income and information-filing requirements for UK retirement plan assets.

Listen as our experienced panel provides comprehensive and practical guidance on the tax reporting requirements and planning opportunities for U.S. taxpayers owning UK-based retirement accounts and pension plans.



  1. SIPPs--status as non-qualified plans
  2. Treaty exceptions and thresholds
  3. Required filings for account ownership
  4. Distribution planning and available elections under treaty
  5. Reporting distributions and claiming U.S. foreign tax credits under IRC 901


The panel will discuss these and other important topics:

  • What types of UK retirement and pension accounts receive deferral treatment under the U.S.-UK tax treaty?
  • How are distributions from UK accounts reported on U.S. tax returns?
  • What are the differences in U.S. treatment of various UK schemes?


Kennedy-C. Edward
C. Edward (Ed) Kennedy, Jr., CPA, JD

Managing Director
C Edward Kennedy Jr

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing...  |  Read More

Cook, Tim
Tim Cook

Wilder Coe

Mr. Cook's areas of tax expertise include tax planning, pension planning, inheritance tax, trusts,and inland...  |  Read More

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