UK Pension taxable in US for US Resident Green card holders

So - how about this. A UK citizen, permanent resident in the US. Files returns etc. etc.

This publication:

https://www.irs.gov/pub/irs-pdf/p901.pdf

from the IRS itself, is a summary of the tax treaties. RE pensions, it says this:

<<
Pensions paid by, or funds created by, the
United Kingdom, its political subdivisions, or local
authorities for services performed for the
United Kingdom are exempt from U.S. income
tax unless the recipient is both a resident and
citizen of the United States.
These exemptions do not apply to income or
pensions for services performed in connection
with a business carried on by the United Kingdom,
its political subdivisions, or local authorities.
Venezuela
Income, other than a pension, p>>

So - if one receives a bog standard UK pension as a result of normal work and contributions, and one is a green card holder and resudent, but not citizen, doesn't this imply the UK pension is NOT taxable in the US?

Pensions paid by, or funds created by, the
United Kingdom, its political subdivisions, or local
authorities for services performed for the
United Kingdom are exempt from U.S. income
tax unless the recipient is both a resident and
citizen of the United States.

This refers to government pensions and they are covered in the Treaty by their own Article. Government pensions may be taxable by the US (and US only) if the two requirements of residence and citizenship apply.

So - if one receives a bog standard UK pension as a result of normal work and contributions,

This is taxable by the US for a 'US Person'. It may also be taxed in the UK if the 'US Person' is resident in the UK.

Ah drat - worth  a try!

Taking a treaty-based position may also be an expatriating act.

Taking a treaty-based position may also be an expatriating act.

Only if the treaty position is that you are not a US resident.

I'm confused - what does a treaty based position have to do with this?

A

It has nothing to do with your situation.  Guya's comment here is not relevant to you.