The Associate Chief Counsel (International) of the US Internal Revenue Service (IRS) has issued a memorandum with an interpretation of Art. 18 (Pensions Schemes) of the 2001 US-UK tax treaty.
The issue presented was whether a US resident could make a tax-deferred rollover distribution from a UK pension scheme to a US retirement plan in circumstances where the distribution would not qualify as an "eligible rollover distribution" under relevant US domestic law (i…