pk
Level 15
Level 15

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@Takumi571 , from a conservative approach, I would assume that this is not a qualified plan and therefore include your total wages as part of foreign earned income ( even though the UK is calling it qualified and thus  not taxing your contribution) i.e. you expose "X" as your earnings to US taxes.  This assures that your basis in the plan  is "Y" per year.   Therefore when you get distribution from your pension plan , you would be taxed by the US on the growth of Y + Z & its growth.  You take the position that this portion is not constructive receipt till distribution.  I think that will be safest way to proceed.

 

If you are willing to take a more aggressive approach ( I really don't see advantage  in this  ), you claim your total wages  is X+Z or X-Y+Z (??) --- the problem with this would be a leaky defense of the constructive receipt principle and when receiving distribution from the plan your basis  may be lower but advantage is you will only pay on the growth ( you have to able to prove that  if challenged ).  It is more complicated  and good records  needed may be 30 years from now (?) and who knows what the rules would be.  

 

None of this would change UK taxing