Unfortunately, @DaveF1006 the burden of proof is on the taxpayer to find explicit support for categorizing income as passive, and I challenge you to find that support for pensions anywhere in the IRS publications, or the tax code, or IRS bulletins, private letter rulings, court cases, etc. Unless you can find explicit support for categorizing it as passive, then the income defaults to general category. There are cases where someone might have what they consider to be pension income, but it is actually an annuity contract, and in that case it fits into one of the explicit types of income that can be considered passive. But for the most part, the income that people think about as "pension" does not meet the definition of "annuity contract". Over a period of decades I've had tax returns filed by three different tax professionals who do nothing but international tax for a living, and they have all been unequivocal that foreign pension income falls in the general category. If you have some support for the opposite position please share it.
