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I am the beneficiary in the UK of a USA Lifetime variable

Resolved Question:

I am the beneficiary in the UK of a USA Lifetime variable select policy. I understand this is a pension policy where I can it I select, choose a lump sum. I am again completing a W7 form for an ITIN. Is the pension policy which I am going to receive covered under treaty article number 17 or 18 as I have seen demonstrated on a US website, as there seems to be some confusion over this?
Thank you.
Submitted: 1 year ago.
Category: Tax
Expert:  TaxRobin replied 1 year ago.

Hello

A beneficiary of an annuity (treated like a pension for US tax purposes) would be taxed on the earnings in the annuity not the initial amount the deceased started it with.

The Lifetime Variable is an annuity and covered under the treaty in Article 17.

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