Which article of the US/UK DTT applies after a Government retirement account like a 401a or a 403b is rolled over to and IRA; Article 19 or 17. I'm leaning towards Article 19 because the money comes out of "funds created by, a Contracting State or a political subdivision or a local authority". Whether it's in a 401a, 403b, IRA etc doesn't matter, it's the source of the money. Am I right? I want to roll my 401a over to an IRA when I leave state employment to simplify my finances and get reduced management fees so it will become an issue.
