All U.S. citizens and residents are subject to tax on their worldwide income. This includes UK pensions. However, you can make an election to apply the US-UK Income Tax Treaty. If you make a proper election on Form 8833, the 25% tax-free lump sum portion of your pension, formally known in the UK as the Pension Commencement Lump Sum (PCLS) that allows you to receive the first 25% tax-free. The default rule is that it's 100% taxable in the U.S. unless and until you affirmatively elect to claim the benefits of the treaty. A private employee pension would only be exempt in the US, if it was tax exempt in the UK.
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