Roth Ira

Here's a question for those of you more expert than I-

I'm a US citizen, UK resident, paying UK tax on the arising basis. I've started receiving the Required Minimum Distribution from my US pension fund  (not a great deal of money). The distribution can be rolled over into a Roth IRA.  I'd pay US tax on the rollover but then none on the subsequent 'interest' and distributions. What would be the UK tax situation on the rollover and on later distributions from the Roth

If I just took the distribution and spent it - is it right that I'd re-source it as UK income by treaty, pay UK tax on it and then take a Foreign Tax credit on my US tax?

(I've not had much luck with the specialists I've consulted)

To contribute to a ROTH you'll have to show taxable income below the ROTH limit on your 1040. ROTH gains and distributions are tax free in the UK to the same extent that they are in the US.....so tax free.

I don't know about how to tax the pension distributions as different pensions are treated differently by the Treaty.

many thanks
the pensions in question are a 401k, 2 403b and a traditional IRA

You can roll 401k, 403b and IRA over into a ROTH directly. Now the issue becomes how to deal with the income and the tax to be paid and for that I think you need to apply the tax treaty.

I don't know the answer, but here's my reasoning, if the rollovers are classed as lump-sum distributions from a pension plan Article 17 paragraph 2 of the tax treaty is applicable, but it isn't exempt from the savings clause so as a US citizen you have to pay US tax on the distributions. I imagine you'll have to show the income on your UK taxes too (as under Article 17 paragraph 2 the UK will want to tax the distributions) and take a credit for any US tax paid.

Any future distributions from the ROTH are tax free in US and UK

Thank you for your reply and what seems to me impeccable reasoning. However my question is slightly different.
I wouldn't be converting the entire amount of, say, my 401k into a Roth. I'd only be rolling over a portion of it (i.e., 1/26th of it, which is the  amount I am required to take each year as a distribution).

I understand that if I converted the entire amount of the 401k it would be a lump sum distribution and the UK wouldn't tax it. But would a conversion to a Roth of only part of the 401k similarly be treated as a lump sum by the UK?

Sorry forgot about the RMD. Well those are annual distributions calculated using actuarial tables so IMHO they would not be classified as lump sum distributions. So You are dealing with Article 17 paragraph 1a and your distributions will be taxed by your state of residence, but you are a US citizen so the savings clause applies. Sounds like you pay US tax on the distributions and take a credit for that against the UK tax you will be required to pay.  ROTH gains and distributions will be free of all UK and US tax as per Article 17 paragraph 1b.

This is just my reading of the treaty and I defer to the professionals and Guya on this