Have a question about tax treaty between South Africa and US as it pertains to Article 18. Taxpayer moved to US in January and took a distribution of his South Africa based pension plan in March. Any hope of excluding it from taxable US income?
Taxpayer and his spouse want to elect to be treated as US residents for the full year to take advantage of lower tax rates. His pension was taxed by SA and the FTC doesn't offset all US tax due to AMT issues. Taxpayer worked for the employer for over 10 years in SA to accumulate benefits. No US based benefits earned.