My issue is that the CPA is considering the transfer a distribution in 2018 and not still a tax deferred transfer when all documentation I can find does not support their evaluation.
I spoke with the IRS international yesterday and they confirmed the documentation from the the 2016 US revised model income treaty that the transfer of the pension to another tax deferred account should not be considered a distribution.
I cashed out the pension in 2019, and will declare the distribution on that return. But do not understand why the CPA is insisting on including it in 2018 when it seems it should still be considered tax deferred even in the US. Plus the distribution creates even more conflict with the 2019 return considering that I am distributing the same pension in the 2 years.