Inherited IRA Tax Implications

Cook_County

Bostonerimus1 said:

Cook_County said:

This is an area on which I advise professionally many times every month. I have also had numerous meetings with senior HMRC policymakers over the last dozen years. HMRC interpret the treaty as giving the right to the UK to charge tax, but with credit for the actual tax due in the US (not the 30% withheld). In essence file both US & UK tax returns, the UK will give a credit for any US tax payable.

So is HMRC now using the Savings Clause to over-ride Article 17.2?

100% correct. This is HMRCs new interpretation.