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Oh so now I'm (possibly) confused.

 

Is this thread talking about a pension earned by working for a specific employer in the UK [which could be the UK government] and paid by that entity to the individual as a result of working directly for that entity?

 

Or is this thread talking about a UK state pension (referenced in one of the emails by its moniker OAP (for Old Age Pension) which is most equivalent to US Social Security?   

 

I believe the first example (pension paid by an employer as a result of working for that specific employer) qualifies per the referenced Treaty and requires the form 8833. 

 

I believe the second example (UK state pension) is not only taxable by the IRS but also NOT subject to the 85% cap and so needs to be reported on a substitute 1099-R or as misc income and NOT as a substitute SSA-1099.

 

Is my understanding correct?

 

As a side comment, does anybody know why TurboTax does not support 8833?  It is just a text response form.  No interaction with any calculations.  It's painful for some people to be forced to mail in their returns for this reason.