Hi, taking a step forward this conversation. We could agree that employee and the employer matching contributions into a UK pension could be 'general limitation' income thus subject to FTC (carryforward and current) from employment in the UK; however, the accretion (likely passive?) on the pension would be unrealized: could the HTKO potentially come into play given the fact that, when it will be taxed in the UK, it will suffer an ordinary rate?
I cannot see the PFIC rules to apply to a pension, but I am not sure.
Overall, how comfortable can we be that the US tax basis of a UK pension, electing out of the treaty protection, will be the employee and employer matching contributions? Apologies if I am asking something that has been discussed before.