By Jonathan Laws, ACA, Ch.FCSI, Series 65, Senior Adviser, Cameron James USA.
If you are reading this, there is a good chance you built up pension savings in the UK through an Aegon SIPP or an Aegon workplace pension, and your life has since moved to the United States. Perhaps you are a British national who relocated for work or family and became a US resident, or a US citizen who worked in the UK for a period and left an Aegon pension behind. Either way, the Aegon pot still sits on a platform designed around UK residents, and it now has to work inside a completely different tax and regulatory system: yours. An Aegon SIPP transfer for a US resident is one of the more frequent reviews we carry out, and it carries considerations that go well beyond the standard non-UK-resident case.
This guide is written specifically for US citizens, Green Card holders and other US tax residents who hold an Aegon SIPP or an Aegon workplace pension. It explains what Aegon does well, where the platform runs into trouble for US persons, the beneficiary drawdown risk that most people have never heard of, and how a UK legacy pension fits inside your US reporting and tax obligations. It is written to be read by a non-specialist, without jargon and without sales pressure.
One development is worth knowing before you read further. On 15 April 2026, Aegon announced an agreement to sell Aegon UK to Standard Life for a total consideration of GBP 2.0 billion, with completion expected around the end of 2026 subject to regulatory approvals.
The announcement is published on the Aegon corporate newsroom and can be read in full here. What that change of ownership will mean for US-resident members has not been published, and we treat it as an open question rather than a settled fact. It is relevant context, because Standard Life has itself been writing to US-resident SIPP holders requiring them to transfer out, as covered in our guide to the Standard Life closure for US residents.
Key Takeaways
Aegon is one of the largest workplace pension providers in the UK, reporting around 8,400 employer schemes and roughly 870,000 scheme members as at 31 December 2025. Most people who hold an Aegon pension hold a workplace arrangement rather than a SIPP they opened themselves.
The US-resident issues are broadly common across the range, covering Aegon Retirement Choices, One Retirement, TargetPlan group personal pensions, employer trust-based schemes, the Aegon Master Trust and legacy Scottish Equitable plans. The transfer mechanics are not common, and that is where cases stall.
The published Aegon SIPP death benefits guide states that a beneficiary must be UK resident for drawdown. A US-resident spouse or child is therefore likely to be offered a lump sum instead, which is the largest avoidable planning risk covered in this guide.
PFIC reporting does not bite on funds held inside a UK pension during accumulation. It bites on what sits outside the wrapper, such as an ISA or a general investment account.
For a US resident an International SIPP is, in the great majority of cases, the right destination. A QROPS very rarely is.
Cameron James USA does not charge an initial advice fee on UK pension transfers or US-connected investments. Ongoing advice, platform and fund charges still apply and are published in full.
Is your Aegon pension still the right home for your retirement?
Under the product terms, a US-resident beneficiary is likely to be offered a lump sum rather than drawdown. A review confirms your position. Fee-based, fees published in full.
Key Point for US Residents
The published Aegon death benefits guide for the Aegon SIPP states that the beneficiary must be a UK resident for drawdown, and that Aegon may only be able to offer a lump sum where that restriction applies. Where a beneficiary lives in the United States, including a US-resident spouse or child, the drawdown route is therefore likely to be closed to them. Combined with the US tax treatment of a large lump sum, this is a planning risk that is avoidable with the right advice.
What Is the Aegon SIPP and Who Uses It?
The Aegon SIPP is a self-invested personal pension provided by Scottish Equitable plc, an Aegon UK company. It is a UK-registered pension scheme. Scottish Equitable plc is authorized by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority, under Financial Services Register number 165548. Aegon also operates two related platforms, Aegon Retirement Choices, known as ARC, and One Retirement. Both share similar product structures and similar limitations for US-resident members.
Aegon is one of the largest pension providers in the UK. The Aegon corporate website describes Aegon UK as a leading investment platform with around 3.7 million customers. If you were employed in the UK at any point in the last fifteen years, there is a reasonable probability that at least part of your pension history sits with Aegon today, even though you now live, work and file taxes in the United States.
The typical client who approaches us about an Aegon SIPP transfer is either a US citizen who spent time working in the UK, or a British national who has since become a US resident or Green Card holder. Many joined a group personal pension arranged by a UK employer, left the UK, and simply retained the plan without ever reviewing it against their US tax and reporting position.
How Aegon Works for US Residents: The Core Limitations
Residency and new business restrictions
In our client-facing experience, Aegon does not generally accept new SIPP applications from residents of the United States. If you are already a member, you may be permitted to retain the plan, but the platform was not built to serve US persons on an ongoing basis. We have not found a published Aegon policy statement setting this out, so treat it as our experience of live cases rather than a quoted rule, and confirm your own position with Aegon in writing. That design gap creates friction across contributions, investment choice, payments, tax reporting and death benefits.
Cross-border payments and currency
The standard Aegon payment infrastructure is built around UK bank accounts. Paying pension income directly to a US bank account, in US dollars, together with the tax documentation needed to claim relief under the US-UK Double Taxation Convention, can be cumbersome and in some cases is not supported. Obtaining an NT code from HMRC so that UK pension income is paid without UK withholding tax adds a further administrative layer, and most of that process lands on the member.
Investment options and US reporting complications
Many clients who joined a workplace Aegon scheme are defaulted into a UK-centric fund panel chosen by a former employer. For a US person that creates a second-order problem beyond suitability. Non-US pooled funds, including UK-domiciled OEICs and unit trusts and EU-domiciled UCITS funds, are generally treated as passive foreign investment companies for US tax purposes. Inside a UK pension the reporting position is different: a reporting exception applies to PFIC interests held through an arrangement treated as a foreign pension fund under an income tax treaty, where the treaty defers taxation of the income of the fund until it is paid to the member. That exception is set out in the regulations under section 1298(f) and can be read in the Code of Federal Regulations. It applies to the pension wrapper. It does not extend to holdings outside the wrapper, for example in a UK ISA or a general investment account. Reviewing the underlying investment approach, and confirming what does and does not sit inside the protected wrapper, is often the single largest source of value in an Aegon review for a US resident.
The Non-US-Resident Beneficiary Problem: Why This Matters Most
This is the issue that most clearly separates a standard UK SIPP from an International SIPP, and it is one where the Aegon product documentation is unusually candid.
What the Aegon Death Benefits Guide Says
The published death benefits guide for the Aegon SIPP, issued by Scottish Equitable plc, lists among the conditions and restrictions on the product that the beneficiary must be a UK resident for drawdown, and states that Aegon may only be able to offer a lump sum where those conditions apply. The guide also confirms that on the death of a member, all investments in the Aegon SIPP are sold and placed in the cash facility. You can read the guide on the Aegon website.
Under current UK pension rules, a nominated beneficiary who inherits an unused drawdown fund can elect for beneficiary drawdown. That is a powerful option. The money stays inside the pension wrapper, it continues to be invested, income can be drawn over time, and whatever is unused can be passed on again to the next generation.
For US-resident beneficiaries, most UK SIPP providers do not hold the authorizations required to service an account for a resident of the United States on an ongoing basis. Aegon is no exception. The practical consequence is that if your spouse or your adult children live in the United States, they will typically not be offered the drawdown option. The only route available to them may be a lump sum encashment.
Why forced encashment is a particular problem for US persons
- A large one-off lump sum can push a US-resident beneficiary into a higher federal and state income tax bracket in the year it is received, because the United States generally taxes the payment as ordinary income where no UK tax was paid on it to generate a foreign tax credit.
- Once the money has left the pension, the ability to cascade what remains to a second generation inside a tax-advantaged wrapper is lost entirely.
- The FBAR and Form 8938 position also changes once a foreign pension account is closed and the proceeds are received as cash, which can raise new reporting questions for the beneficiary.
- Because all investments are sold on death under the terms of the Aegon SIPP, the timing of that sale is set by the scheme and not by the family, which introduces market timing risk at the worst possible moment.
There is a further reason to review nominations now rather than later. Finance Act 2026 received Royal Assent on 18 March 2026 and, for deaths on or after 6 April 2027, most unused pension funds and pension death benefits will be brought within the value of the estate of the deceased person for UK inheritance tax purposes. HMRC has published a technical note on the change. How that interacts with a US-resident beneficiary, with the spouse exemption and with the residence-based rules that replaced domicile from 6 April 2025 depends on individual circumstances, and it needs modeling alongside a specialist adviser rather than a general assumption. What is clear is that death benefit planning for a UK pension is now a two-jurisdiction exercise with a fixed deadline attached to it.
An International SIPP is designed to serve US-resident members and their beneficiaries. The trustees and administrators are set up to support cross-border servicing, so a US-resident beneficiary can elect for beneficiary drawdown, keep the funds invested inside the pension wrapper, and continue to receive advice from an adviser authorized to work with US clients.
The Position for US Persons: FBAR, PFIC and the Pension Commencement Lump Sum
For US citizens, Green Card holders and other US tax residents, an Aegon pension creates a specific set of considerations that sit alongside, and often outweigh, the general non-UK-resident issues described above. Cross-border treatment is governed by the US-UK Double Taxation Convention.
Annual reporting
The annual FBAR obligation applies where the aggregate value of foreign financial accounts exceeds 10,000 US dollars at any time during the calendar year, and a UK pension counts toward that total. The IRS sets out the requirement on its FBAR page. Form 8938 applies at higher thresholds that depend on filing status and on whether you live inside or outside the United States. For a specified individual living in the United States, the thresholds are more than 50,000 US dollars of specified foreign financial assets on the last day of the tax year or more than 75,000 US dollars at any time during the year, doubling to 100,000 and 150,000 US dollars for a married couple filing jointly. The IRS publishes a side-by-side comparison of Form 8938 and the FBAR. Filing one does not relieve you of the obligation to file the other.
PFIC reporting inside and outside the wrapper
As a general matter, and this is the point most clients have never had explained to them clearly, funds held inside a UK registered pension are outside the scope of annual PFIC reporting during the accumulation phase, on the basis of the treaty pension fund exception described above. That exception attaches to the wrapper. It does not extend to investments held outside it. If you also hold a UK ISA, a general investment account or directly held UK or EU-domiciled funds, those holdings can carry Form 8621 reporting for each fund for each year, and the default Section 1291 regime is punitive. Specialist US tax advice should always be sought on the specific position.
The 25 percent pension commencement lump sum: genuinely unsettled
The treatment of the UK 25 percent pension commencement lump sum is the single most contested point in this area, and any guide that presents it as settled is overstating the position. Under UK rules the lump sum is normally paid free of UK tax, capped by the Lump Sum Allowance, reported as 268,275 pounds for the 2025 to 2026 tax year unless protection applies. Article 17(2) of the US-UK Double Taxation Convention provides that a lump sum payment derived from a pension scheme established in one state and beneficially owned by a resident of the other is taxable only in the state where the scheme is established, which on its face points to the UK alone. The convention text is available on legislation.gov.uk. The counter-argument, which is the mainstream practitioner position, is that the saving clause in Article 1(4) permits the United States to tax its own citizens and residents as if the convention did not exist, and that Article 17(2) is not among the provisions preserved from that clause.
Our working position, and the position we plan around, is that a US person should expect the lump sum to be taxed as ordinary income in the United States, with any treaty position disclosed rather than assumed. We flag it as unsettled because it is: the two readings above are both live, HMRC has already revised its own stance on the mirror-image question of US lump sums paid to UK residents, and the outcome for you turns on facts a general article cannot see. This is a decision to make before any crystallization event, with your US tax adviser and a cross-border pensions specialist in the room. We set out the full Article 17 analysis, what changes if the entitlement is drawn gradually through UFPLS rather than in one payment, and the US state tax position including California, in our guide to whether the UK 25 percent tax free lump sum is taxable in the US.
Aegon Transfer Options for US Residents: International SIPP, Not QROPS
If an Aegon SIPP or Aegon workplace pension no longer serves your circumstances as a US resident, an International SIPP is, in the overwhelming majority of cases, the right transfer route. This is a more clear-cut conclusion for US persons than for non-UK-resident clients generally, for reasons specific to US tax law. Our wider treatment of the subject sits in our pillar guide to UK pension and SIPP transfers for US residents.
What an International SIPP actually is
An International SIPP is structurally identical to a standard UK SIPP. It is a registered pension scheme in the UK, listed with HMRC, and it stays inside the UK regulatory framework. The difference is that the platform, the trustee and the administration are all built to serve US-resident clients: payments to US bank accounts, multi-currency support, an investment universe accessible to US-resident investors, and the ability to offer beneficiary drawdown to a US-resident spouse or child. Annual platform costs are typically modest, and several of the providers we work with are competitive on an absolute basis against well-known UK platforms.
| For a US resident | Aegon SIPP or Aegon workplace pension | International SIPP | QROPS |
| Scheme status | UK registered pension scheme | UK registered pension scheme | Overseas scheme recognized by HMRC, outside the UK system |
| Built to service US-resident members | No | Yes | Rarely, and most trustees decline US persons |
| Income paid to a US bank account in US dollars | Not generally supported | Supported | Varies by jurisdiction and trustee |
| Beneficiary drawdown for a US-resident beneficiary | Restricted. The product terms require the beneficiary to be a UK resident for drawdown | Available | Varies, and rarely the deciding factor |
| 25 percent Overseas Transfer Charge on the transfer | Not applicable | Not applicable, because both schemes are UK registered | Applies unless the member is resident in the same country as the scheme |
| Typical US reporting profile | FBAR and Form 8938 | FBAR and Form 8938 | FBAR and Form 8938, plus foreign trust reporting on Form 3520 and Form 3520-A where the scheme is treated as a foreign trust |
| Our view for a US resident | Review it, do not assume it is safe | Usually the right answer | Almost never appropriate |
Table: how the three routes compare for a US-resident member. Product terms and trustee policies vary, so confirm the position for your own plan before acting.
Why QROPS is almost always the wrong answer for US persons
- A QROPS, or qualifying recognised overseas pension scheme, is a pension structure established outside the UK, typically in a jurisdiction such as Malta, Gibraltar or the Isle of Man. For US persons specifically, a QROPS creates two compounding problems that rarely apply to other non-UK-resident clients in the same way.
- The 25 percent Overseas Transfer Charge applies to most QROPS transfers unless the member is resident in the same country as the scheme. The former exclusion for schemes established in the European Economic Area or Gibraltar was removed with effect from 30 October 2024, and HMRC sets out the charge in its Pensions Tax Manual. Because there is no QROPS established in the United States, a US resident transferring to an offshore QROPS will in practice trigger the charge.
- A QROPS held by a US person is commonly treated as a foreign trust for US tax purposes, which brings the arrangement within Form 3520 and, in many cases, Form 3520-A reporting. That is materially more burdensome than the FBAR and Form 8938 reporting that applies to a UK registered pension held directly, and penalties for getting foreign trust reporting wrong are severe and assessed independently of whether any tax was due. The IRS publishes the instructions to Form 3520, and a limited exemption for certain tax-favored foreign retirement trusts exists under Revenue Procedure 2020-17, although many offshore schemes do not meet its conditions. Our detailed treatment of this sits in our guide to Malta QROPS reporting and Form 3520.
For these reasons we do not generally recommend a QROPS to US-resident clients. An International SIPP remains a UK registered pension scheme, is not treated as leaving the UK system, and does not trigger the Overseas Transfer Charge, because the transfer takes place between two UK registered pension schemes. We should be precise about one point, because it is often overstated in this market: whether any given UK pension requires foreign trust reporting is a fact-specific question on which cross-border tax advisers do not entirely agree, and it should be settled by your own tax adviser rather than by an adviser brochure.
A Note From Jonathan Laws
Transferring Out of Aegon: The Safeguarding Process
Since 30 November 2021, UK pension legislation has required trustees and managers of registered schemes to carry out due diligence checks before processing a transfer request, in order to protect members from pension fraud. The relevant rules are the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021, available on legislation.gov.uk. Aegon applies these checks to transfer requests, including requests from US-resident members.
The regime is commonly described in the industry as a traffic light system. Where the trustees identify a red flag, the transfer cannot proceed as a statutory transfer. Where they identify an amber flag, the transfer can proceed only after the member has taken pension safeguarding guidance from MoneyHelper, the service delivered by the government-backed Money and Pensions Service. The member then receives a unique reference number, which is provided to the ceding scheme to release the transfer. One of the amber flags is triggered where the receiving scheme includes overseas investments, which is why International SIPP transfers are so often routed through a MoneyHelper appointment. The guidance appointment is provided at no cost to the member.
This is an area of live change, and it is worth stating plainly rather than glossing. In June 2026 the Department for Work and Pensions opened a consultation on amending the 2021 regulations which proposes removing the overseas investments amber flag altogether and allowing trustees to proceed without enhanced due diligence where they are satisfied the receiving scheme is reputable. The consultation closed on 21 July 2026. As at the review date of this article the proposals are not law, the 2021 regulations continue to apply as drafted, and you should plan on the basis of the current rules while expecting the position to move.
Avoiding Transfer Delays
Cameron James USA advisers are SEC authorised, alongside the individual authorisations relevant to UK pension advice. Advice on your Aegon transfer is therefore given on a properly authorised basis for a US-resident client, and we support the whole process, including any MoneyHelper safeguarding requirement.
Aegon Workplace Pensions for US Residents: TargetPlan, Master Trust and Group Personal Pensions
Which Aegon workplace arrangement do you actually hold?
This is the first question to settle, because the answer changes the process rather than the conclusion. Aegon delivers workplace pensions through several structures. TargetPlan supports three types of defined contribution scheme: a contract-based pension, most commonly a group personal pension or group stakeholder plan, a trust-based pension run by your employer’s own board of trustees, and the Aegon Master Trust, a multi-employer arrangement governed by a single independent trustee board in which each employer has its own section. Separately, many employers use the workplace version of Aegon Retirement Choices, and a large number of older arrangements still sit on legacy Scottish Equitable contracts, Aegon UK being the trading name under which those were written. Aegon reports around 8,400 employer schemes and roughly 870,000 scheme members as at 31 December 2025, which is the reason so many of the US-resident enquiries we receive turn out to be workplace money rather than self-directed SIPP money.
Your annual statement will usually name the arrangement, and the Aegon employer and adviser pages set out the ranges. If it is not clear, the practical test is who you contract with. A contract-based plan is a personal pension in your own name and your instruction is sufficient. A trust-based scheme or a master trust section is an occupational arrangement, and the transfer is made by trustees on your behalf rather than by you.
Why the transfer mechanics differ from a SIPP
For a contract-based group personal pension the route is essentially the SIPP route described earlier in this guide, and the safeguarding checks apply in the same way. Where the arrangement is trust-based or sits inside the Aegon Master Trust, an extra layer is involved. The trustees, not Aegon as administrator, exercise the discretion to make the payment, so the timetable depends on the trustee board’s own process as well as the provider’s. In our experience this is the most common source of delay on Aegon workplace cases, and it is worth requesting the transfer discharge paperwork and the scheme’s current transfer-out procedure at the outset rather than discovering the requirement three weeks in.
It is also worth checking what your particular section will and will not pay directly. Some workplace arrangements offer the full range of flexible retirement options, while others expect a member who wants flexible access to move to a different plan first, and a member living in the United States may find that internal move is itself restricted. Where that is the case, the choice is not between staying flexible and transferring. It is between a constrained UK arrangement and a structure built for a cross-border member.
The default investment strategy was not built for a US resident
Members of a workplace scheme who never made an active fund choice sit in the scheme default, which for TargetPlan is most commonly LifePath, or a lifestyle strategy designed for that specific employer. These strategies automatically de-risk as a target retirement date approaches. That design assumes a member who will draw sterling income in the UK on a broadly predictable date. For someone who is now US resident, whose spending currency is dollars, whose retirement date has often moved, and whose tax position is governed by the US-UK Double Taxation Convention rather than by UK rules alone, an automated glidepath selected by a former employer is unlikely to be the right answer by default. It may still be defensible, but it should be a decision rather than an inheritance.
Two further points apply once you have left the employer. Employer contributions stop, so the only remaining value in the arrangement is the platform, the fund range and the charge, and workplace fund ranges are typically narrower than retail ones. The Aegon Master Trust range, for example, is published as a deliberately concise selection. And the reporting position is not changed by the workplace label: the pension is reportable on FBAR and potentially Form 8938 in the same way as a SIPP, and the PFIC shelter that applies inside the wrapper applies equally. Our page on defined contribution transfers sets out how these cases are assessed, and because Cameron James USA charges no initial advice fee on a UK pension transfer, establishing whether a move is worthwhile does not cost you anything to find out.
What This Means for You
If you are a US resident holding an Aegon SIPP or an Aegon workplace pension, the most important step is to carry out a structured review rather than assume the status quo is safe or that the position is simply too complicated to deal with. For some clients the conclusion will be to remain invested with Aegon for now. For many others, particularly those with a US-resident spouse or children named as beneficiaries, a transfer into an International SIPP will produce materially better long-term outcomes: cleaner FBAR and Form 8938 reporting, income withdrawals that work with the US-UK Double Taxation Convention, and the ability to pass the pot down through beneficiary drawdown rather than through a forced and heavily taxed lump sum.
Frequently Asked Questions
Can I keep my Aegon SIPP if I live in the United States?
In most cases, yes. Existing members are generally permitted to remain in the plan after becoming a US resident. However, your ability to contribute meaningfully will be limited, and the ongoing suitability of the platform for a US person may be poor, particularly on investment options, payment infrastructure, US tax reporting and death benefits. A review will confirm whether staying put or transferring is the stronger answer for your situation.
What happens to my Aegon pension when I die if my beneficiaries live in the United States?
This is the single most important question for US-resident pension holders. The published Aegon death benefits guide states that the beneficiary must be a UK resident for drawdown, and that Aegon may only be able to offer a lump sum where such restrictions apply. If your nominated beneficiaries live in the United States, the likely outcome is a lump sum death benefit, which can produce a large and potentially heavily taxed payment that removes all future planning flexibility. An International SIPP is structured to avoid that outcome.
Do PFIC rules apply to my Aegon SIPP?
Generally the annual reporting does not apply during the accumulation phase, because a reporting exception covers PFIC interests held through an arrangement treated as a foreign pension fund under an income tax treaty where the treaty defers taxation until payment. PFIC reporting becomes relevant where you hold non-US collective investments outside the pension wrapper, for example in a general investment account or an ISA. Specialist US tax advice should be sought on any specific holding.
Will transferring from Aegon to an International SIPP trigger a US or UK tax charge?
A transfer from an Aegon SIPP or group personal pension into an International SIPP is a recognized transfer between two UK registered pension schemes. It does not trigger a UK tax charge and is not treated as a distribution for US purposes. The pot moves across on a like-for-like basis. What drives your tax position is the timing and structure of any later income drawdown, which should be planned against the US-UK Double Taxation Convention and your federal and state position.
Should I consider a QROPS instead of an International SIPP?
For a US resident, almost never. A QROPS held by a US person is commonly treated as a foreign trust, which brings Form 3520 and Form 3520-A into play with severe penalties for errors, and most QROPS transfers by a US resident also trigger the 25 percent Overseas Transfer Charge now that the European Economic Area and Gibraltar exclusion has been removed. An International SIPP remains a UK registered pension scheme and avoids the Overseas Transfer Charge on transfer.
How long does an Aegon SIPP transfer usually take?
In our experience, an Aegon transfer to an International SIPP typically completes within six to twelve weeks, depending on how quickly any MoneyHelper safeguarding appointment is completed and on the responsiveness of the receiving provider. We manage the process end to end.
Do I need to liquidate my investments before transferring from Aegon?
In most cases, yes. Transfers between UK SIPP platforms are generally carried out as cash transfers: existing investments are sold, the cash moves to the new provider, and the new portfolio is built at the receiving end. The timing of the sale and the reinvestment is part of the advice process.
Does the sale of Aegon UK to Standard Life change anything for me?
Not yet, and we would rather say so than speculate. Aegon announced the agreement on 15 April 2026 and expects completion around the end of 2026, subject to regulatory approvals. No published statement sets out what the change of ownership means for US-resident members. It is a reason to review your position now with your eyes open, not a reason to act in haste.
Speak to an adviser who works in both systems
If you hold an Aegon SIPP or workplace pension as a US resident, a short structured review will tell you whether to stay or transfer, and will put the beneficiary position and the US reporting position in writing.
Related Articles
If this guide was useful, these pages cover the neighboring questions that Aegon clients usually ask next.
UK Pension and SIPP Transfer for US Residents: Your Complete Guide
The pillar guide. Transfer options, US taxation of UK pension income, adviser regulation, costs and the full process, step by step.
Standard Life Aberdeen SIPP Closing for US Residents
A live example of a major UK platform withdrawing from US-resident servicing, and what an enforced transfer deadline looks like in practice.
Malta QROPS Tax Reporting for US Residents: Form 3520 and IRS Treatment
The foreign trust reporting question in detail, including the position where a Malta scheme is already in place.
Is The UK 25 Percent Tax Free Lump Sum Taxable In The US?
The treaty analysis behind the section above, including the UFPLS sequencing question and the US state tax position.
