The Associate Chief Counsel (International) of the US Internal Revenue Service (IRS) has issued a memorandum with an interpretation of Art. 18 (Pensions Schemes) of the 2001 US-UK tax treaty. The issue presented was whether a US resident could make a tax-deferred rollover distribution from a UK pension scheme to a US retirement plan in circumstances where the distribution would not qualify as an "eligible rollover distribution" under relevant US domestic law (i.e. Section 402(c)(4) of the US Internal Revenue Code). The IRS noted that numerous taxpayers and practitioners have argued that the rollover should qualify for tax-deferred treatment on...