UK Pension Schemes - PFIC Reporting

Hello Fello Yankees!

I was researching the topic of PFIC reporting on UK pension schemes and found a lot of contradictory information. Lately, I stumbled upon this interesting read from PwC:
https://www.pwc.com/gx/en/services/people-organisation/publications/assets/pwc-united-states-pfic-guidance-provides-new-reporting-exceptions.pdf

Specifically, it mentioned that "all applicable foreign pension funds (or equivalents) under any type of arrangement regardless of their classification for US federal tax purposes. This exception applies for any beneficiary of, participant in, a plan, trust, scheme, or other arrangement that is treated as a foreign pension fund if an income tax treaty states that any income from the fund is only taxed
when it is paid to the shareholder. There are several treaties that include such a provision, though many apply only if the IRS has specifically agreed that the foreign plan generally corresponds to a US plan which may require a specific competent authority request submission (some provide for 'automatic' treatment for plans). Certain treaties provide relief only for contributions to foreign pensions, but not earnings, and thus this exception would not apply. ".

My questions are:
 - Does anyone know which final Treasury Regulations PwC is talking about?
 - Does anyone know if IRS has agreed that UK pension plans correspond to a US plan? If so, which specific UK schemes were qualified?
 - What does everyone do in regards to PFIC reporting for SIPPs, ISAs, Personal Pension Schemes (PPPs)?

Thank you for your help!
 

The following comments may be of some assistance.
•   Article 18 of the double tax treaty deals with pension schemes.
•   Article 18(2)(b) confirms that pension benefits are only taxable when paid to the individual.
•   Article 18(5)(a) restricts the above to generally corresponding pension arrangements.
•   The US response within the Exchange of Notes on the treaty says that schemes listed under the Note dealing with Article 3(1)(o) are to be treated as generally corresponding.
•   As regards UK schemes the list specifies UK approved schemes, and makes reference to now repealed definitions, but it is to be read as covering later equivalent rules. This can reasonably be taken as covering UK registered pension arrangements.
•   SIPPS and personal pensions are registered UK pensions schemes.
•   ISAs are not within the above rules so ISA investments might include some where the PFIC rules could apply.

I believe there are some funds that have registration in both the US and UK (Vanguard for one) where you can park your pension and its ok.

I believe there are some funds that have registration in both the US and UK (Vanguard for one) where you can park your pension and its ok.

That is not correct. All offshore funds could apply to HMRC for reporting status. Because of mifid the fund manager would have to be one that wants to sell funds within the EU & is OK with EU & UK regulation.  The fund itself is still located in its home jurisdiction.  The FCA, HMRC or the fund manager could choose to terminate reporting status without prior notification to an investor.