.png.3b3332cc2256ad0edbc2fe9404feeef0.png.8488ab72b8bb2e508209bfe3211b6e08.png)
-
Recently Browsing 0 members
- No registered users viewing this page.
-
Topics
-
-
Popular Contributors
-
Latest posts...
-
321
Russia Rejects Trump's Temporary Ukraine Ceasefire Offer
just to update the guy that you were answering to, (he's on my ignore list)had to point out the guy is the master of trolling and spreading lies, should pass him the latest updates US Begs Europe to Share Their Eggs But Will Likely Be Denied Amid Rising Prices https://www.ibtimes.com/us-begs-europe-share-their-eggs-will-likely-denied-amid-rising-prices-3766341 -
140
Tax Filing Experience: Jomtien [March-2025]
Interesting discussion of the treatment of private pensions including ROTH distributions in the Technical 2006 Model (note that the sections are different from the 1996 Thai-U.S. conventions which has this as Article 20. https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-2006.pdf ARTICLE 17 (PENSIONS, SOCIAL SECURITY, ANNUITIES, ALIMONY, AND CHILD SUPPORT) This Article deals with the taxation of private (i.e., non-government service) pensions and annuities, social security benefits, alimony and child support payments. Paragraph 1 Paragraph 1 provides that distributions from pensions and other similar remuneration beneficially owned by a resident of a Contracting State in consideration of past employment are taxable only in the State of residence of the beneficiary. The term "pensions and other similar remuneration" includes both periodic and single sum payments. The phrase pensions and other similar remuneration is intended to encompass payments made by qualified private retirement plans. In the United States, the plans encompassed by Paragraph 1 include: qualified plans under section 401(a), individual retirement plans (including individual retirement plans that are part of a simplified employee pension plan that satisfies section 408(k), individual retirement accounts and section 408(p) accounts), section 403(a) qualified annuity plans, and section 403(b) plans. Distributions from section 457 plans may also fall under Paragraph 1 if they are not paid with respect to government services covered by Article 19. In the other Contracting State, the term pension applies to: [ ]. The competent authorities may agree that distributions from other plans that generally meet similar criteria to those applicable to the listed plans also qualify for the benefits of Paragraph 1. Pensions in respect of government services covered by Article 19 are not covered by this paragraph. They are covered either by paragraph 2 of this Article, if they are in the form of social security benefits, or by paragraph 2 of Article 19 (Government Service). Thus, Article 19 generally covers section 457, 401(a), 403(b) plans established for government employees, and the Thrift Savings Plan (section 7701(j)). However, the State of residence, under subparagraph (b), must exempt from tax any amount of such pensions or other similar remuneration that would be exempt from tax in the Contracting State in which the pension fund is established if the recipient were a resident of that State. Thus, for example, a distribution from a U.S. "Roth IRA" to a resident of the other Contracting State would be exempt from tax in the other Contracting State to the same extent the distribution would be exempt from tax in the United States if it were distributed to a U.S. resident. The same is true with respect to distributions from a traditional IRA to the extent that the distribution represents a return of non-deductible contributions. Similarly, if the distribution were not subject to tax when it was “rolled over” into another U.S. IRA (but not, for example, to a pension fund in the other Contracting State), then the distribution would be exempt from tax in the other Contracting State. -
1
-
38
-
100
Another example of Trump's IQ level
I think I can pick the difference between brain farts and sarcasm. I don't know if you have noticed Trump is installing people in every position he can reach, who have only one qualification - absolute loyalty. What makes you think the military would be exempted? -
170
Democrats Face Backlash for Supporting Arrested Palestinian Activist Mahmoud Khalil
He is and was allowed to voice his opinion . He is being deported for attacking USA citizens on campus and also other crimes committed . His group were invited to voice their opinion in a classroom, but they refused that offer . He was bringing the Middle East war with him to the USA .
-
-
Popular in The Pub
-
-
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now