UK/US Tax treaty and 401ks, 403bs, IRAs etc

In the UK/US tax treaty Articles 17 and 18 deals with the taxation of "Pensions, social security, annuities,
alimony and child support". Luckily the las 2 items don't conern me. I assume (dangerous I know) that
US Tax deferred retirement accounts like 401k, 403b and IRAs are defined as pensions fo the sake of this agreement

Yes, BUT...  The savings clause in Article 1 paragraphs 4 and 5 may affect the interpretations of Articles 17 and 18.

Yes, BUT...  The savings clause in Article 1 paragraphs 4 and 5 may affect the interpretations of Articles 17 and 18.

Thanks, Article 1, paras 4 and 5 seem to be "cover your ass" paragraphs where the Contracting States agree
that either party can ignore the the Covention if they want. This seems sensible as both states wants to be able
to tax their citizens and or residence according to their own laws which might change over time.

The saving clause is in ALL US treaties.  Only very few parts of other articles over-ride the saving clause in the US/UK treaty.  Be extremely careful if you plan on claiming treaty benefits as a US citizen!

The saving clause is in ALL US treaties.  Only very few parts of other articles over-ride the saving clause in the US/UK treaty.  Be extremely careful if you plan on claiming treaty benefits as a US citizen!

The forms for foreign tax credits are pretty straight forward and while the instructions on the IRS and HMRC are quite long winded ploughing through them
is worthwhile. Care is always a good thing when filling out tax forms.

I am not sure that the US instructions adequately describe resourcing of foreign income under the US/UK treaty and the UK manuals are certainly wrong on US pensions if one is non-UK domiciled, not ordinarily resident in the UK or one has basis in the US pension.  Incidentally neither country quite agrees on which plans are foreign pensions covered by the treaty so full and adequate disclosure is a must on either set of tax returns.  This is where expert advice is invaluable...