@MMCMAR , generally this should not be considered active/self-employed income and therefore there is no FICA/SECA on this. My question is why do you have to surrender and get a total distribution and what prevents it from being left in the trust and distributed as pension after you are retired ( UK does have a retirement age --no?). Even if you don't do that you could still avail yourself of lump-sum total distribution and average over 10 years once you reach a certain age. Or are you taking the total distribution for some personal requirements.
I would strongly suggest you consult a tax professional familiar with international retirement income and USA-UK tax treaty , before you take distribution.
On the other hand if you have already taken the distribution , then perhaps you can answer my questions and we will find help for you
pk
