From what I’ve read “lump-sum” is not well defined in the US and open to interpretation. In the US the 25% is can be interpreted as a partial distribution not a...
Update. I was just made aware of an IRS issued informational letter in written in 2008 basically saying Article 17 doesn't apply and the UK PCLS remains taxable...
re "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...
