@Djritxist In my opinion and finding no direct reference to PPK in the US-Poland Tax of 2013 ( even though there is reference to pension/annuity etc. ) and because this a voluntary participation " savings scheme ", one way to do this would be to generate a dummy 1099-R i.e. treat it like an annuity ( with no 1099-R issued and no EIN for the administrator). Use Box -1 -- gross distribution; Box 2a -- the gain as the taxable amount ( just as in Poland ); Box 2b checked ( Total distribution ), Box 7 use code 7 (Normal Distribution).
This should then allow IRS to tax you on the gain .
Thereafter claim Foreign Tax credit by using form 1116 -- Gross Foreign Income is the Taxable amount; Foreign Tax is what you paid to Poland.
Does this make sense ?
