IRA distributions / withholding tax rate to IRS


I am US citizen and living in Japan for +20 years (my tax-base is Japan).

I am curious about anyone taking RMDs from a regular-IRA and the calculation of appropriate withholding tax rate to the IRS. According to the IRS document "W-4R 2024 Withholding Certificate for Nonperiodic Payments and Eligible Rollover Distributions", it mentions "Generally, you can’t choose less than 10% for payments to be delivered outside the United States and its territories."

I have been more doing more research on this, specifically at https://www.irs.gov/retirement-plans/plan-distributions-to-foreign-persons-require-withholding

I am wondering if the Japan-US income tax treaty is structured so that a payee (as a resident in the treaty country Japan), can enjoy a U.S. tax exemption on the qualified plan distributions.

I have been re-reading different threads on IRS distributions here, especially this thread, https://www.reddit.com/r/JapanFinance/comments/xkmrjf/ftc_for_usbased_investment_income_ira/

However it is still very unclear to me.

I would be grateful for any information/experience regarding this.

by Exciting-Sky5394

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