Foreign Pension distribution – subject to penalty?

A resident alien in the U.S. is taking a distribution from his pension in Switzerland. He is 52 years old. My understanding is this will be fully taxable in the US based upon the US-Swiss Tax Treaty.

My question is whether or not this distribution is subject to the 10% early distribution penalty? I assume it is not since the pension plan does not meet the IRS’s definition of a qualified retirement plan.

Thanks for your input.



Is an early distribution from a Swiss Pension subject to the 10% Penalty?



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