Client (54 years old) and his wife 53 yrs old are US permanent resident and both citizens of the UK. Have been living in the US since
2014. He has a pension plan in the UK from his previous employment there, projected to be valued at $ 1,000,000 by 12/31/19 with a cost basis of $ 400,000. At age 55 (in 2020) he can take distributions from his UK pension plan without incurring a penalty from the UK but he will have to pay tax in the UK on 75%; the first 25% withdrawal is tax free there. His 2020 other income in the US will be about $25,000 salary and $ 20,000 interest income. Questions
1. Can he convert that $ 1 million UK pension plan via a tax free rollover to a traditional deductible US IRA.
2. Thus his ratio of taxation on distributions in year 2020 in the US will be 40% (400,000/1,000,000) ?
3. Presumably for 2020 if he can convert tax free it to an IRA he will have to pay a 10% penalty additionally if he takes distributions in 2020 because he is not 59 1/2 in 2020?
4. He would like the IRA rollover option because if he takes all of the $1,000,000 in 2020 he will have a huge US tax.
5. Apparently his only options at age 55 (in year 2020) on this plan from the UK are take it all out; or take some distributions or leave it invested as is in the UK. But the yield in this plan in the UK is very low Taking it out could mean a “transfer to an IRA, if possible”, to avoid the huge one time tax and get better yields in IRA investments in the US gong forward.
6. He has other investments that he plan to cash in in 5 years. and then suspend taking distributions from this pension plan, until age 70 1/2 if it could be converted to an IRA.

To summarize
He wants to take money from the $ 1,000,000 UK pension plan for about 5 years from (2020 to 2024). Then stop withdrawals and continue keeping it and growing it until age 70 1/2 when he will have to take mandatory RMD from the IRA if this plan can be converted to an IRA
For years 2025 to to 2036( age 59 to age 70) he will taking out funds from another annuity and/or other investments.