Since there seem to be other people struggling with US pension funds and Roth conversions, etc. I'm setting out my circumstances and my reasoning in trying to see my way through the thicket. Converting to a Roth doesn't seem a great deal for me but it could well be that my reasoning is faulty (and of course, other people will have different circumstances).
I have $160k that I could convert to a Roth. As is, it earns 3% interest a year. This and my other income should be sufficient for my needs for the rest of my life (say, for 25 years, the approximate amount figured in the actuarial tables).
Assuming that the 160k taxed at the ordinary US rates, it would kick me up to higher tax brackets so I'd pay about 25% US tax on it, or 40k. (I don't know if it would kick me into having to pay Alternative Minimum Tax). I wouldn't pay any UK tax on this conversion. Distributions would be tax free in both jurisdictions for the rest of my life. My dependents are all comfortable and don't particularly need an inheritance. So, how many years of tax would recoup the 40k in tax I'd already paid.
From this fund, I'm currently taking distributions of $6800 (around 4% a year, as per RMD requirements). For my current needs, I don't need more.
On these distributions of $6800 I pay US tax of 15%. After the UK 'discount' of 10%, I pay UK tax of 18%, ie., yearly US tax of $1000 and UK tax of $1200. (These rates are lower than the tax rate I'd have to pay to convert to a ROTH).
Here's where I get hung up: Assuming I stayed in the UK and paid UK tax, AND I remained in the UK 20% bracket, it would take 33 years to recoup the $40k I'd already paid.
If I died in 25 years, with the Roth conversion, I would have paid $40,000 in US tax. Without converting to a Roth, and just paying UK tax on the yearly distribution, I would have paid $30,000 in UK tax. IRS would be $10,000 ahead. If I died earlier, I'd lose even more.
I could take out more in yearly distributions in order for it to be tax efficient. But in order to make it last 25 years, I shouldn't take out more.
What am I missing?