US/UK DTA Article 18 Roth Conversions

The US/UK DTA Article 18 (1)  States:

   Where an individual who is a resident of a Contracting State is a member or beneficiary of, or participant in, a pension scheme established in the other Contracting State, income earned by the pension scheme may be taxed as income of that individual only when, and, subject to paragraphs 1 and 2 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of this Convention, to the extent that, it is paid to, or for the benefit of, that individual from the pension scheme (and not transferred to another pension scheme).

Are Roth Conversions subject to this provision and are they taxable in the US or UK?

Thanks in advance

This recently updated thread on this subject is worth reading.

https://talk.uk-yankee.com/index.php?topic=97389.0

This recently updated thread on this subject is worth reading.
https://talk.uk-yankee.com/index.php?topic=97389.0

Thanks for that.

It appears that the majority of current opinions, as was mine till recently, are that conversions are US taxable and UK tax exempt.

This has changed my opinion. I received a 1042-S for 2020 that reports the Roth conversion as Treaty Exempt which means I have no way reporting this as income on a 1040NR so it is in fact US tax exempt according to this. What I do not have is a definitive opinion from HMRC  as to their position on Roth conversions. Does anyone have an HMRC opinion on this?

I did pay estimated US taxes on the conversion for 2020 so should now file a 1040NR to claim a refund.

What a mess. 

Thanks for that.

It appears that the majority of current opinions, as was mine till recently, are that conversions are US taxable and UK tax exempt.

This has changed my opinion. I received a 1042-S for 2020 that reports the Roth conversion as Treaty Exempt which means I have no way reporting this as income on a 1040NR so it is in fact US tax exempt according to this. What I do not have is a definitive opinion from HMRC  as to their position on Roth conversions. Does anyone have an HMRC opinion on this?

I did pay estimated US taxes on the conversion for 2020 so should now file a 1040NR to claim a refund.

What a mess.

Hopefully someone more knowledgeable will come along an offer an opinion. I only know about my own circumstances as a US citizen living in the UK.  If the IRS says it is not taxable in the US then I would think it is taxable in the UK, I can't see a tax deferred IRA suddenly becoming tax free simply because one has moved back to the UK.  See what HMRC have to say, particularly if you approach them with the fact that you made a lump sum withdrawal from your IRA rather than periodic withdrawals.