I have a client who would like to move money from a SIPP in the UK to a US based profit sharing plan. The client is a US citizen living in the US. I don't think the UK/US tax treaty would allow such a transfer but I'm not clear on this. Has anyone brought foreign retirement money into a US 401(a) plan or possibly an IRA.

Draper

Why would the individual feel the need to do this? My recollection is that the new US-UK tax treaty would compel the US to recognize the tax deferred nature of the UK arrangement. Thus the individual would not be subject to US or UK tax on the funds while held in the arrangement. But I don't have the treaty in front of me . . .

Probably some similar discussion in earlier threads.

Might also help to refer to tax treaty.
http://www.irs.gov/pub/irs-trty/