By Jonathan Laws, ACA, Ch.FCSI, Senior Independent Financial Adviser, Cameron James USA.
Hargreaves Lansdown SIPP for US Residents: US Tax, Reporting, and Your Options
If you are a US resident, whether an American who worked in the UK or a British national who has moved to the States, and you hold a Hargreaves Lansdown SIPP, you are in a specific and frustrating position. You can usually keep the account. You cannot really use it. Hargreaves Lansdown does not service US residents, so the SIPP sits there holding whatever it held on the day you moved, while the two systems you now have to satisfy, HMRC in the UK and the IRS in the US, carry on regardless.
This guide starts with what that actually means day to day, because it is the part people underestimate, then covers how the pension is treated for US tax purposes, the reporting that applies, and the route most US residents end up taking. None of this is personal tax or investment advice. Cross-border pension planning is one of the most nuanced areas in personal finance, and the right answer depends on your circumstances. What follows is a general explanation to help you ask better questions.
Holding a frozen HL SIPP from the US?
Book a free initial consultation and we will review what you hold and what your options are, through advisers authorized in both the UK and the US.
Key Takeaways
- Hargreaves Lansdown does not service US residents. You cannot open a new HL SIPP, and HL will not accept a transfer in from a US resident.
- An existing HL SIPP can usually be retained, but it is effectively frozen: no new contributions, no new fund purchases, and no consolidating other pensions into it.
- The freeze is a servicing decision, not a tax one. The pension itself remains a UK-registered pension, recognized under the treaty, with growth typically tax-deferred for US purposes.
- PFIC reporting does not apply to funds held inside the pension wrapper. It becomes a concern for investments held outside a pension, such as a general investment account or an ISA.
- You will usually still need to report the pension on your FBAR, FinCEN Form 114, and often on Form 8938.
- An NT code lets a UK provider pay you gross when you draw benefits, so the income is taxed in the US rather than withheld in the UK and reclaimed.
- Advice to a US person must come from an SEC-registered adviser, and an International SIPP managed by a dual-regulated adviser, FCA and SEC, is the route most US residents use.
What the Hargreaves Lansdown SIPP Is, and Why It Stops Working
Hargreaves Lansdown is the largest direct-to-consumer investment platform in the UK, and the HL SIPP is one of the most widely held do-it-yourself pensions in the country. That popularity is the point. It is designed, marketed and priced for a UK resident managing their own investments, with a fund supermarket, research and tools built entirely around that one customer.
None of that survives a move to the United States. Hargreaves Lansdown no longer accepts new SIPP applications or pension transfers from non-UK residents, and it does not service US residents. For anyone who spent years consolidating their pensions into one place precisely so that everything sat under a single login, this is a particularly irritating outcome, because the consolidation strategy that made sense in the UK is the thing that now leaves the largest single pot stranded.
What frozen actually means, day to day
The word gets used loosely, so it is worth setting out what it does and does not cover, because the practical consequences are not obvious from the outside.
- No new contributions. Even where you retain UK relevant earnings in the first years after leaving, the platform will not take them.
- No new fund purchases. You can generally sell, but not buy, which over time turns any active strategy into a slow liquidation into cash rather than a rebalance.
- No consolidation in. Any other UK pension you later want to bring together has to go somewhere else, which defeats the reason most people chose the platform.
- Cash accumulates without a home. Dividends and the proceeds of any sale land in the cash account, where they sit rather than being reinvested, and inflation does the rest.
- The asset allocation drifts. A portfolio built for a UK resident in the accumulation phase is left to run without rebalancing, so the risk profile changes on its own over the years.
- Currency is unmanaged. Your liabilities are now in dollars and the account is entirely in sterling, with no facility to address that.
None of these is dramatic on any given day. That is precisely why the position persists for years. There is no letter, no deadline and no crisis, just a pension quietly doing something other than what you would choose if you could choose.
The returning resident exception
If you expect to move back to the UK within a short and reasonably certain timeframe, the calculation is different. HL options reopen once you are UK resident again, and transferring out and back can cost more than it saves. Where a return is genuinely planned rather than merely hoped for, leaving the account alone and managing around it can be the right answer. Where the return is indefinite, the drift described above compounds for as long as the position lasts.
This is not specific to Hargreaves Lansdown
The same pattern runs across the UK direct-to-consumer market. Fidelity UK, Vanguard, Interactive Investor, AJ Bell and Bestinvest have all stepped back from US-resident clients. The reasons are consistent: the compliance burden of FATCA and FBAR reporting, and US securities rules that make it problematic for a UK-only platform to let a US resident trade without the oversight of an SEC-registered adviser. We have covered several of these as they happened, including Interactive Investor, Vanguard and Bestinvest. If you are waiting for the market to soften on this, the movement has been in one direction for a decade.
Your Hargreaves Lansdown SIPP Compared With an International SIPP
| Feature | Hargreaves Lansdown SIPP | International SIPP |
| Accepts US residents | No | Yes |
| Transfers in from US residents | Blocked | Accepted |
| Platform or investment fee | 0.45 percent tiered, indicative | 0.25 to 0.40 percent typical, some fixed around 400 pounds, indicative |
| Trustee or administration fee | Included | 150 to 250 pounds a year typical, indicative |
| Investment options | UK-based, restricted for non-residents | Global, multi-currency, US-aware |
| Adviser support | Do-it-yourself only | Dual-regulated adviser, FCA plus SEC |
Table: indicative comparison only. Fees and features vary by provider and change over time. These figures are illustrative and are not a quote. Confirm the current schedule for any provider before you commit.
Your Situation, and What to Do Next
| Your situation | Can you use HL as a US resident? | Your next step |
| Already living in the US | No, Hargreaves Lansdown does not service US residents | Move to an International SIPP with a dual-regulated adviser |
| Moving to the US soon | Transfers in are blocked once you are US resident | Act before the move, or use an International SIPP |
| Already hold an HL SIPP | Keep it, but it is frozen | Get a US-compliant review and consider consolidation |
| Returning to the UK later | HL options reopen when you are UK resident | Resume with HL, or stay in the International SIPP |
Table: the four positions US-connected HL clients are usually in, and where each one leads.
How the Pension Is Treated Under US Tax Rules
The servicing problem above is separate from the tax position, and it is worth keeping the two apart. Losing access to the platform does not change what the pension is or how it is taxed. This section is a summary of the general position for any UK registered pension held by a US person, and applies equally whichever provider holds it.
The treaty
A UK-registered pension is generally recognized under the Double Taxation Treaty between the US and the UK, so growth inside the pension is normally tax-deferred for US purposes until you draw benefits, rather than being taxed year by year. The treaty is what stops your UK retirement savings from being treated as an ordinary taxable investment account by the IRS. The IRS publishes the UK treaty documents in full.
The 25 percent UK tax free lump sum needs care. The US does not automatically mirror the UK treatment, and the position is contested rather than settled: the mainstream practitioner view treats it as taxable in the US, a minority argues otherwise under the treaty, and no court has decided the question. Plan it in advance with your US tax adviser rather than assuming an answer.
PFIC
PFIC reporting does not apply to investments held inside a UK pension wrapper. The mechanism is worth knowing, because it tells you where the boundary falls: a reporting exception applies to PFIC interests held through an arrangement treated as a foreign pension fund under an income tax treaty, set out in the regulations under section 1298(f) and readable in the Code of Federal Regulations. It attaches to the wrapper. PFIC becomes a live issue for investments held outside a pension, such as a general investment account or an ISA, and on any assets sold during a transfer. Our guide to PFIC restrictions for US-connected investors covers that in full.
Reporting
Most US persons need to include a UK pension on their FBAR, FinCEN Form 114, and above the relevant thresholds on Form 8938. They apply at different thresholds and are not alternatives; the IRS publishes a comparison. These are disclosure requirements rather than extra taxes, but the penalties for missing them can be significant. There is a further grey area around whether a UK pension is a foreign grantor trust requiring Forms 3520 and 3520-A. Workplace pensions with employer contributions are often viewed more favourably than personal arrangements with no employer input, positions differ, and a limited exemption exists under Revenue Procedure 2020-17. Get a US tax adviser to confirm your filing position.
The NT code
When you start drawing, the treaty generally gives the US the right to tax your regular pension income, but a UK provider may still deduct UK tax at source unless an NT code is in place. You apply to HMRC through the US-Individual claim process, and the provider then pays gross. It is a practical but easily missed step, and it is one of the things we handle as part of a transfer. We cover it in more detail in our guide to the UK State Pension, tax and the NT code.
The Compliant Route: an International SIPP With a Dual-Regulated Adviser
An International SIPP is a UK-regulated, HMRC-registered pension, structurally the same as a standard SIPP in tax treatment, contribution rules and retirement benefits. The difference is that it is built to accept and service non-UK residents, including US persons, and to be managed alongside a US-compliant portfolio. Our pillar guide to UK pension and SIPP transfers for US residents sets out the process end to end, and our review of the IFGL SIPP shows how we assess a receiving scheme.
The advice element is the part that most often goes wrong. A UK-only FCA adviser cannot give fully compliant, insured advice to a US tax resident, because FCA authorization does not extend to US securities law. Advice to a US person needs to come from an SEC-registered adviser. Cameron James USA advisers hold individual SEC authorization, and work with clients on a fee-based basis.
How Cameron James USA Helps, Step by Step
- Residency and regulatory check
We confirm your current and future residency and check eligibility across UK and US rules, so the plan fits your actual situation. For an HL client this is also where the returning resident question gets answered honestly, because if you are moving back soon the right advice may be to do nothing. - Platform selection
We shortlist FCA-regulated International SIPP providers that accept and properly service US residents, matched to your cost and platform preferences. - Portfolio construction
We build a US-compliant, low-cost, globally diversified portfolio, structured to avoid PFIC problems on any holdings outside the pension wrapper. - Transfer and paperwork
We handle the letters of authority, discharge forms, NT tax code application and provider communications, moving assets in specie where possible and planning carefully where anything must be sold. - Ongoing advice and oversight
We provide fee-based advice, periodic rebalancing, and joined-up cross-border planning across UK and US tax, currency and retirement income.
Talk to a dual-regulated adviser
Cross-border pensions need advice that works on both sides of the Atlantic, including the NT code, the transfer paperwork and a US-compliant portfolio.
A Note From Jonathan Laws
Frequently Asked Questions
Can I keep my Hargreaves Lansdown SIPP if I live in the United States?
Usually yes, but it is effectively frozen. You cannot make new contributions, buy new funds, or consolidate other pensions into it, and Hargreaves Lansdown will not accept a transfer in from a US resident. The account continues to exist and to be valued, it simply cannot be managed.
Is my Hargreaves Lansdown SIPP taxed by the US while it grows?
Generally no. Under the treaty between the US and the UK, growth inside the pension is typically tax-deferred for US purposes until you draw benefits. Your specific position should be confirmed with a US tax adviser.
Do PFIC rules apply to my Hargreaves Lansdown SIPP?
Not to the funds held inside the pension wrapper, where a reporting exception applies to interests held through a treaty-recognized foreign pension fund. PFIC becomes relevant for investments held outside a pension, such as a general investment account or an ISA.
What is an NT tax code and why does it matter for US residents?
An NT code, meaning No Tax, tells your UK provider to pay your pension gross. Because the treaty generally gives the US the right to tax your UK pension income, an NT code stops UK tax being deducted at source, so the income is taxed once, in the US, rather than being withheld in the UK and reclaimed.
Can I manage my Hargreaves Lansdown SIPP from the US?
Not through Hargreaves Lansdown, which does not service US residents. The compliant route is an International SIPP managed by an FCA-authorized, SEC-registered adviser.
I am moving back to the UK in a couple of years. Should I still transfer?
Possibly not. HL options reopen once you are UK resident again, and if the return is genuinely planned and reasonably near, transferring out and back can cost more than it saves. Where the return is indefinite, the case for moving is much stronger, because an unmanaged portfolio drifts for as long as the position lasts. This is a question worth putting to an adviser rather than answering from an article.
Will transferring to an International SIPP trigger a UK or US tax charge?
A transfer between two UK registered pension schemes does not trigger a UK tax charge and is not treated as a distribution for US purposes. What drives your tax position is the timing and structure of later withdrawals, not the transfer itself. Where holdings have to be sold rather than moved in specie, the sale is inside the pension wrapper and is not itself a taxable event.
I am a UK expat in the US rather than a US citizen. Does this apply to me?
Yes. What drives both the platform restriction and the US reporting is US tax residence rather than nationality. A UK national who is US tax resident faces the same freeze and the same obligations.
Talk to a dual-regulated adviser
Cross-border pensions need advice that works on both sides of the Atlantic, including the NT code, the transfer paperwork and a US-compliant portfolio. Cameron James USA advisers hold individual SEC authorization.
Related Articles
These are existing Cameron James USA articles covering the questions HL clients usually ask next.
UK Pension and SIPP Transfer for US Residents
The transfer pillar. Options, US taxation of UK pension income, adviser regulation, costs and the full process.
International SIPP
How the wrapper works, and how it differs from a standard UK SIPP for a member living abroad.
Interactive Investor SIPP Closing for US Residents
The same market pattern at another large platform, with an enforced deadline attached.
Vanguard UK Closed Your Account Because You Live in the US?
Why Vanguard treats US persons differently from other overseas clients, and how to respond.
UK Expat Retirement Planning in the US
How a UK pension, US accounts and State Pension entitlement fit together for an expat in the States.
The IFGL SIPP Review 2026
How we assess whether a receiving International SIPP is the right destination, and what it costs.
Information:
Where this article includes information from other parties, we use sources we consider reliable, but we cannot guarantee that all of it is accurate or current. Nothing in this article is legal, accounting or tax advice. Rules in these areas are complex and depend on your personal circumstances. Please take advice from a qualified professional if required.
Jonathan Laws, ACA Ch.FCSI
Senior Independent Financial Adviser, Cameron James
“When a platform like Hargreaves Lansdown restricts you, it is not the end of your pension options, it is the point where you start doing things properly. An International SIPP gives US residents the compliance, flexibility and servicing that a UK-only platform no longer can.
What I would add is that HL clients are often the most reluctant to move, and I understand why. These are usually people who took an interest, consolidated deliberately, and ran the portfolio themselves for years. Being told the platform will not deal with you feels like a demotion. It is not. The account is frozen whether you move it or not, and the only question is whether the money spends the next decade drifting or being managed. If you are genuinely heading back to the UK soon, leave it alone and I will tell you so. If you are not, the drift is the expensive option.”