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Topic: IRA withdrawals how will it be taxed in UK and US?  (Read 1570 times)

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IRA withdrawals how will it be taxed in UK and US?
« on: April 16, 2020, 02:01:28 PM »
Hi, I know this topic has come up many times before but I still can't really understand how it will actually work, so pls bear with me and all advice will be gratefully received! ( this is also my first post!)
Background.
US and UK citizen, now resident in UK and likely to remain so. I file both UK and US returns each year.
Now retired (64) , UK pension income will be about GBP 37,000 pa. I also get US SS of about 900 USD per month on top.
I have an IRA ( with Vanguard) with a balance of about 600K USD, and this is what I want to start withdrawing from, I thought about 36K USD pa.
So my total global income would be about 90K USD pa.
Am I right in thinking the process would be as follows:-
1. I would ask Vanguard to sell funds and transfer the equivalent of 36K into my US bank account , say split into 4 tranches of 9K each qtr , per year. Will they deduct any tax at source? Or can I just tell them that I will settle up on tax owed on my UK and US tax returns?
2. When I come to complete my US return I would add all my UK / US income and file.
3. On my UK return I would do the same but would have  a tax liability on both the US social Security and IRA distributions, all based on the UK tax rates.
4. Given UK tax is higher that US tax I would likely not have to pay any additional US tax.
Is that pretty much it, I also assume the IRA cannot be treated towards my 25% UK tax free lump sum allowance??
Are there any other ways to reduce my US ( or I guess UK tax liability?) - transfers to Roth IRA?
Appreciate any advice / guidance anyone can give, thanks !




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Re: IRA withdrawals how will it be taxed in UK and US?
« Reply #1 on: April 16, 2020, 04:13:29 PM »
That sounds exactly right.  I converted all my IRA money to Roth to avoid paying HMRC tax on IRA withdrawals as lump sum conversions are only taxed by the USA and Roth withdrawals are tax free in both countries.

Having said that, when I make a Roth withdrawal with Vanguard I am prompted to say if I want to make a tax withholding or not so I would expect would also be case with regular IRA withdrawals.

I would send Vanguard a message and ask them.

Dual USC/UKC living in the UK since May 2016


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Re: IRA withdrawals how will it be taxed in UK and US?
« Reply #2 on: April 16, 2020, 05:44:36 PM »
Hi,
This is where I get a bit confused, you say ' I converted all my IRA money to Roth to avoid paying HMRC tax on IRA withdrawals as lump sum conversions are only taxed by the USA' that sounds a very sensible approach, but I guess it can't be a simple process of converting to Rot  lower tax.
Could you explain a bit more , is this option open to me??


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Re: IRA withdrawals how will it be taxed in UK and US?
« Reply #3 on: April 16, 2020, 07:22:13 PM »
Hi,
This is where I get a bit confused, you say ' I converted all my IRA money to Roth to avoid paying HMRC tax on IRA withdrawals as lump sum conversions are only taxed by the USA' that sounds a very sensible approach, but I guess it can't be a simple process of converting to Rot  lower tax.
Could you explain a bit more , is this option open to me??

It is covered in the Double Taxation Agreement, article 17 section 2.  I believe it is still an option for yourself.  It has to be a one-off lump sum. I had started doing this before moving back then did 2 lump sums in successive tax years after returning to the UK.  I used a dual qualified Tax preparer to do both my UK and US tax returns.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/507431/usa-consolidated_-_in_force.pdf

Quote
2. Notwithstanding the provisions of paragraph 1 of this Article, a lump-sum
payment derived from a pension scheme established in a Contracting State and
beneficially owned by a resident of the other Contracting State shall be taxable only in
the first-mentioned State.

Dual USC/UKC living in the UK since May 2016


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Re: IRA withdrawals how will it be taxed in UK and US?
« Reply #4 on: April 17, 2020, 09:06:18 AM »
That's really helpful. I will take a look.


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