If you live in the United States and hold UK pension savings, you have probably found that most UK pension providers will not deal with you. Interactive Investor, Vanguard UK, Hargreaves Lansdown and a long list of others have closed their doors to US residents. The Novia Global SIPP is one of the few UK pensions built to accept you. This review sets out what it does well, where it falls short for a US resident, what it costs, how the US tax and PFIC position works, and how a transfer into it is done from the States.
It is written for two readers in equal measure: UK expats and British expats in the US who built up pensions in the UK before moving, and US citizens and green card holders who worked in the UK and came home with a UK pension. The pension rules are the same for both. How you arrived at the problem is usually different, and we cover both routes.
UK pension still in the UK, and you in the States?
We will tell you whether Novia Global is the right home for it, handle the transfer, and show you where everything else you hold should sit.
Key Takeaways
- Our verdict: a sound, transparent, low-cost SIPP that accepts US residents, but for most US residents the Morningstar International SIPP is the better choice. Morningstar pays interest on cash and Novia Global does not, and Morningstar gives access to US-domiciled funds, which Novia Global does not accept at all.
- A US resident can hold a Novia Global SIPP, through an adviser holding SEC authorization. There is no self-invest route: see Can You Self-Invest in a Novia Global SIPP?.
- Inside the SIPP, PFIC tax is generally not expected during accumulation, because a reporting exception applies to PFIC interests held through a treaty-recognized foreign pension fund. Reporting may still apply.
- Novia Global does not accept US-domiciled funds, and its General Investment Account is not available to US persons. ISAs and other money outside the pension need a different, PFIC-compliant home.
- Charges are a fixed £240 a year SIPP fee, no set-up fee, a tiered platform charge from 0.30% stepping down to 0.10% above £2.5m, and 0.04% fund custody. Taking benefits adds £150 a year, £200 for each crystallization and £13.50 for each payment out.
- Most UK pensions can be transferred into it while you live in the US. Defined benefit transfers need specialist advice first.
- Withdrawals are paid in sterling, so drawing income from the US needs a currency plan.
Can a US Resident Hold a Novia Global SIPP?
Yes. The Novia Global SIPP accepts non-UK residents, and it accepts US persons into the SIPP itself, provided the account is opened and run through a regulated adviser who is permitted to advise you where you live. For a US resident, that means an adviser holding SEC authorization. That condition is not a formality. It is the part of the structure that keeps the arrangement compliant on the US side.
There are two limits a US resident needs to know about from the outset:
- The Novia Global General Investment Account is not available to US persons. The pension wrapper is open to you, but the non-pension investment account is not. If you have savings outside your pension, they need a separate home.
- Novia Global does not accept US-domiciled funds onto its platform at all. US equity exposure inside a Novia Global SIPP is always held through a UK or Ireland-domiciled fund. Inside the pension that is not expected to produce a PFIC tax charge, for the reasons set out below, but it is a genuine difference from the Morningstar International SIPP.
Neither point rules Novia Global out. They define the scope within which it works well for a US resident, and they explain why we often pair it with, or compare it against, Morningstar Wealth International.
The Novia Global SIPP at a Glance
The Novia Global SIPP is a UK-registered Self-Invested Personal Pension, launched in June 2020 and administered by Novia Global Limited, the international arm of the Novia Financial group. In law there is no difference between a SIPP and what the market calls an International SIPP. An International SIPP is simply a UK SIPP that accepts non-UK residents properly, rather than tolerating them until a compliance review closes the account. Because it stays inside the UK pension system, it keeps its status as a pension under the US-UK tax treaty, which is what makes it workable for a US resident.
Pension assets are held in trust, separately from the assets of Novia Global, and custody sits with BNY Mellon Pershing (Channel Islands), part of one of the two largest custodian groups in the world. For a US resident moving a lifetime of UK pension savings, that institutional backing is worth knowing about.
| At a glance | Novia Global SIPP |
| Wrapper | UK-registered SIPP, recognized as a pension under the US-UK tax treaty |
| Open to US residents? | Yes, into the SIPP, through an SEC-authorized adviser |
| General Investment Account for US persons? | No |
| US-domiciled funds? | Not accepted on the platform. US exposure via UK or Ireland-domiciled funds |
| PFIC inside the SIPP? | Reporting exception generally applies during accumulation. PFIC tax not expected, reporting may still apply |
| Custodian | BNY Mellon Pershing (Channel Islands) |
| Self-invest option? | No. Adviser-led only |
| Investment currencies | Sterling, US dollar, euro, Australian dollar, Swiss franc, Hong Kong dollar and others |
| Withdrawal currency | Sterling. Other currencies possible, but at two FX costs |
| Core charges | £240 a year SIPP fee, tiered platform charge from 0.30%, 0.04% custody |
| Interest on cash | None paid, on a minimum 2% cash holding |
Table: the Novia Global SIPP at a glance for a US-resident member, as published at the review date.
What Has Changed for 2026
- Platform charge bands are now set in sterling. The tiers previously ran in US dollar bands. They now run from 0.30% on the first £300k down to 0.10% above £2.5m, so the band your pension falls into no longer moves with the exchange rate. Older reviews quoting dollar bands are out of date.
- Automated regular drawdown. Income can now be paid automatically monthly, quarterly or twice yearly, which suits a US resident who needs a predictable income.
- The verdict has moved. Morningstar Wealth International now pays interest on cash and gives access to US-domiciled funds, and for most US residents that makes it the better choice. We set out why below.
Investment Choice Inside a Novia Global SIPP From the US
The platform offers a wide range of mutual funds, exchange traded funds and bonds, which can be held in sterling, US dollars, euros and several other currencies inside the sterling wrapper. Your adviser builds and manages the portfolio; there is no execution-only dealing.
For a US resident the range has one firm boundary: Novia Global does not accept US-domiciled funds. US equity exposure is held through UK or Ireland-domiciled funds instead. Inside the pension that is not expected to produce PFIC tax, but reporting may still apply, and anyone who wants to use US-domiciled funds to take PFIC out of the picture needs a different platform.
How Safe Is a Novia Global SIPP?
- Assets held in trust. Pension assets are held separately from the assets of Novia Global, so they are not available to its creditors.
- Institutional custody with BNY Mellon Pershing (Channel Islands).
- UK regulation. Novia Global Limited is authorised and regulated by the Financial Conduct Authority, firm reference 653661. The Financial Services Compensation Scheme may apply in the event of firm failure, subject to eligibility and the scheme limits in force.
- Safe to hold from the US. For a US resident, the bigger risk is usually not provider failure but a provider that does not accept US residents and closes the account. Novia Global accepts US persons into the SIPP by design.
Our Verdict: The Novia Global SIPP for US Residents
This is our view as advisers who place US residents on the platform. It is not a rating, and it is not a recommendation for any individual: whether Novia Global is right for you depends on everything else you hold.
In short: Novia Global is a well-run, transparent SIPP that a US resident can use, but it is not our first choice for US residents. For most, the Morningstar International SIPP is the better option, for two reasons. Morningstar pays interest on cash held in the account, and Novia Global does not. And if you are concerned about PFIC, the ability to invest in US-domiciled funds makes Morningstar the only option of the two, because Novia Global does not accept them.
Strengths
- Low, predictable cost. A fixed SIPP fee and a sterling-tiered platform charge make the total cost easy to forecast and to audit.
- Transparency. Advisers cannot be paid hidden fees or trail commission through the platform, and clients can see their total costs since day one.
- Built for non-UK residents. Accepting US persons is a designed-in feature, not a tolerance that a later compliance review can withdraw.
- Multi-currency investing. The portfolio can be held in US dollars and other currencies inside the sterling wrapper.
- No set-up fee, and no platform or custody charge on cash.
- A fully FCA-regulated platform. The Novia Global investment platform is regulated in the UK by the Financial Conduct Authority, as well as the SIPP itself.
- Foreign currency withdrawals planned. Novia Global plans shortly to allow benefits to be crystallized and withdrawals paid in foreign currencies, which would let a US resident draw income in dollars.
Limitations for a US resident
- Charges for taking benefits. A £150 a year drawdown charge, £200 for each benefit crystallization event and £13.50 for each payment out, so the cost of taking income rises with how often you crystallize and draw. Morningstar charges one flat £125 a year income charge instead.
- Exit charges. £250 to transfer out to another UK pension and £1,000 to an overseas pension.
- No interest on cash. Novia Global requires a minimum 2% cash holding and pays no interest on it, and drawdown portfolios often hold more. Morningstar pays interest on cash, at 1% below the Bank of England base rate on sterling and 0.35% below the US Federal Reserve rate on US dollars.
- No US-domiciled funds. US equity exposure comes through UK or Ireland-domiciled funds. Inside the pension that is not expected to create PFIC tax, but reporting may still apply, and anyone who wants US-domiciled funds to take PFIC out of the picture cannot do so on Novia Global.
- No home for non-pension money. The General Investment Account is closed to US persons.
- No annual US tax report. Your CPA or Enrolled Agent works from standard platform statements.
- Sterling withdrawals, for now. Until the planned foreign currency option launches, dollar spending means a currency conversion on every payment.
- Adviser-only. There is no execution-only option.
Who it suits
- US residents whose UK money is entirely in pensions and who are not concerned about PFIC reporting, particularly existing Novia Global members, where the cost of moving can outweigh the difference.
- Existing Novia Global members who have moved to the US and want to stay with the provider.
- Mixed-nationality households, where the non-US spouse holds their own SIPP.
Who should look at Morningstar instead
- Most US residents. The Morningstar International SIPP pays interest on cash and gives access to US-domiciled funds.
- Anyone concerned about PFIC. US-domiciled funds are the way to take PFIC out of the picture, and Morningstar is the only one of the two that offers them.
- Anyone with an ISA, UK funds or cash to invest outside the pension, who will need the Morningstar US Taxpayer Service in any case.
Who the Novia Global SIPP Suits in the US
UK expats and British expats in the US
This is the most common profile we see. You built up workplace pensions or a personal pension in the UK, moved to the US for work or family, and your UK provider has either written to you about your US address or will once it finds out. Consolidating into a SIPP that is designed for non-UK residents ends the cycle of closures and gives you one place to manage the money from the US. It also matters on death: a provider that properly accepts non-UK residents can pay death benefits to your beneficiaries in line with your nominations, rather than forcing a cash-out that your family then has to untangle across two tax systems.
US citizens and green card holders with a UK pension
If you worked in the UK and came home with a UK pension, the planning is the same. The difference is usually that you have been in the US tax system throughout, so the pension may already sit on your FBAR and Form 8938, and you are more likely to hold US-domiciled investments elsewhere. The question is less about finding a provider that will accept you and more about fitting the UK pension into a US-compliant whole.
Mixed-nationality households
Where one spouse is a US person and the other is not, each pension is assessed on its own. A Novia Global SIPP can work for both, but the non-pension planning will usually differ between you, which is exactly where a single adviser seeing the whole household earns the fee.
Pre-move window
Moving to the US soon? The weeks before your US residency start date are the most valuable planning window you will get. Your pension is not the urgent part: a UK SIPP remains a recognized pension before and after the move. Your ISAs and UK funds held outside the pension are the urgent part. They were not PFICs when you bought them, but they become PFICs for you on the day you become a US tax resident. Decisions taken before that date can change the US tax outcome materially. That is a question for a US CPA or Enrolled Agent, and we coordinate with yours before the move rather than after it.
How to Transfer Your UK Pension to Novia Global From the US
Most people looking at Novia Global from the US are not opening a pension from scratch. They are moving existing UK pensions, often because the current provider has written to them about their US address. You can transfer while living in the US, and the process is the same in outline for a UK expat and a US citizen.
Which pensions can be transferred
- Personal pensions and SIPPs, including those with providers that now restrict US residents. If your provider has written to you, our Interactive Investor guide shows what that usually looks like.
- Workplace defined contribution pensions and master trusts, usually once you have left that employer.
- Defined benefit, or final salary, schemes. Where the transfer value is over £30k, UK rules require advice from a Pension Transfer Specialist before the scheme will release the money. Our final salary transfer guide covers how this works for US residents.
- Pensions already paying an annuity generally cannot be moved.
How the transfer works
- Review. We collect details of every UK pension you hold, including transfer values, any guarantees or protected benefits, and any exit charges that would be lost or triggered.
- Recommendation. You receive a written recommendation, with full costs, on which pensions to move and which to leave where they are.
- Application. The Novia Global SIPP is opened through us using electronic signatures, so nothing needs to be signed or posted from the UK.
- Transfer requests. Novia Global requests the money from each ceding scheme. Some schemes ask for extra verification when the member has a US address, and we handle that correspondence.
- Investment. Money usually arrives as cash and is invested in line with the agreed strategy. Some holdings, particularly from another SIPP, can move in specie, depending on the holding and the ceding scheme.
- Ongoing. The portfolio is reviewed with you twice a year, and your CPA or Enrolled Agent is given what they need for FBAR and your return.
How long it takes
Timescales are set mainly by the ceding scheme. A straightforward defined contribution transfer often completes within a few weeks. Schemes that run additional checks, or several pensions moving at once, take longer. Defined benefit schemes guarantee a transfer value for a limited period, usually three months, so the advice and paperwork need to be run to that deadline.
The US side of a transfer
Moving between UK registered pension schemes keeps the money inside the UK pension system, which is what preserves its treatment as a pension under the US-UK tax treaty. Cashing out to move the money does not. How the transfer is reported on your US return is a question for your CPA or Enrolled Agent, and we coordinate with them before the transfer rather than after it.
PFIC and the Novia Global SIPP: What Applies Inside the Wrapper and What Does Not
PFIC, the Passive Foreign Investment Company rules, is the single biggest source of confusion for US persons with UK investments, so it is worth being precise.
Inside the SIPP: PFIC tax generally does not bite
Almost every UK or Ireland-domiciled fund, index fund or exchange traded fund is a PFIC in the eyes of the Internal Revenue Service. Held personally, they are taxed punitively and each one needs an annual Form 8621. Held inside a UK SIPP, the position is different. A reporting exception applies under the section 1298(f) regulations to PFIC interests held through an arrangement treated as a foreign pension fund under an income tax treaty, where the treaty defers taxation of income until it is paid out. The SIPP is recognized as a pension under the US-UK tax treaty, so a Novia Global SIPP can hold UK and Ireland-domiciled funds for a US resident without PFIC tax being expected during accumulation. Reporting may still apply in some circumstances, and your CPA or Enrolled Agent should confirm the position on your own facts.
It also explains why the absence of US-domiciled funds on the platform is not a deal-breaker for the SIPP itself. US equity exposure is still available through UK or Ireland-domiciled funds, and inside the pension those funds are not expected to carry the PFIC tax penalty.
Outside the SIPP: this is where PFIC bites
Once money is outside the pension wrapper, the position reverses. A UK ISA is tax free in the UK but not in the US, and UK funds held in an ISA or a general investment account are PFICs. Because the Novia Global General Investment Account is not available to US persons, and Novia Global does not offer US-domiciled funds, Novia Global cannot be the home for the non-pension money of a US resident. This is the same wall US-connected investors hit at Fidelity and elsewhere. Two situations come up again and again:
- Existing ISAs and UK investment accounts. These usually need restructuring into a PFIC-compliant portfolio. In specie transfer is often available and is frequently used deliberately, so the holdings can move first and the PFIC position can be resolved as a separately timed decision, with your CPA, once they are on the new platform. Our guide to keeping a UK ISA as a US resident covers the ISA rules in full.
- Money that leaves the pension. Tax free cash or income you do not spend straight away, if reinvested, needs to go into US-compliant investments, not UK funds.
For both, we typically use the Morningstar Wealth International US Taxpayer Service, which can hold qualifying US-domiciled funds for US persons and produces annual US tax reporting. A Novia Global SIPP for the pension, with Morningstar for the non-pension money, is a structure we use regularly. For some clients, consolidating everything with Morningstar is simpler. That is a case-by-case decision, and it is one of the first things we model.
Cameron James USA does not charge an initial advice fee on US-connected investments, such as your ISA and investment accounts. Our ongoing advice fee and the platform and fund costs still apply.
US Tax and Reporting on a Novia Global SIPP
A Novia Global SIPP does not remove your US tax obligations. It organizes them. The points below are the ones that shape planning for a US resident. We are not tax advisers, and each needs confirming with a US CPA or Enrolled Agent on your own facts.
- Tax deferral during accumulation. Under the US-UK tax treaty, at Articles 17 and 18, growth inside a recognized UK pension is generally not taxed in the US until it is paid out. Consolidating into a SIPP preserves that status. Cashing out, or moving to the wrong structure, can lose it.
- FBAR and Form 8938. A UK pension is generally a foreign financial account for FBAR purposes and counts toward the FinCEN Form 114 threshold of $10k in aggregate. Form 8938 may also apply, depending on your filing status and asset levels.
- Income in retirement. Pension income is generally taxable in the US as your country of residence, with UK tax relieved under the treaty. Getting the UK NT, or no tax, code in place matters, so income is not taxed twice while you wait for relief.
- The 25% tax free lump sum. It is free of UK tax, but the general consensus among the US tax advisers we work with is that it is not automatically tax free in the US, particularly if taken all at once. Some states, California in particular, do not follow the treaty position at all. Phased withdrawals can change the picture. This is an area to model before, not after, you take benefits, and we cover it in detail in our guide to the 25% lump sum.
- US withholding tax inside the SIPP. US withholding tax applies to US-source dividends and income, but not capital gains. For SIPP members, our working view, having consulted several tax advisers, is that no US withholding tax is expected, since the position is assessed at scheme level. This is not formal tax advice.
Novia Global SIPP Fees and Charges
The Novia Global cost structure is one of the main reasons we use it for US residents. It is short, fixed where it can be, and easy to audit. The figures below are from the Novia Global fee schedule that applies to Cameron James USA clients. Charges are published by the provider, are subject to change on notice, and should be confirmed against the current schedule before any decision.
SIPP charges
| Charge | Amount |
| SIPP service charge | £60 per quarter in advance, £240 a year |
| Establishment charge | None |
| Income drawdown charge | £150 a year, while drawdown is active |
| Benefit crystallization event charge | £200 per crystallization event |
| Overseas pension transfer in | £250 per transfer |
| Transfer out to a UK pension | £250 per transfer |
| Transfer out to an overseas pension | £1,000 per transfer |
| Beneficiary benefit distribution | Up to £1,000, only where there is no valid expression of wishes less than two years old, or beneficiaries dispute the payment |
| Ad hoc administration | £100 an hour, in exceptional circumstances, confirmed in advance |
Table: Novia Global SIPP charges from the 2026 schedule applying to Cameron James clients. Any VAT payable is included within these charges.
Platform service charge
The platform charge is tiered on a marginal basis: each rate applies only to the slice of the account within that band, and it is taken monthly. The bands are set in sterling, so the band your pension falls into does not move with the exchange rate. Neither the platform charge nor the custody charge applies to money held in cash.
| Account value | Annual rate |
| Up to £300k | 0.30% |
| £300k to £750k | 0.25% |
| £750k to £2.5m | 0.15% |
| Over £2.5m | 0.10% |
Table: Novia Global tiered platform charge, applied marginally.
Custody, dealing and other charges
| Charge | Amount |
| Custodian service charge | 0.04% a year of the account value, excluding cash, in addition to the platform charge |
| Fund dealing | £4 per trade in a UK, Luxembourg or Ireland-domiciled fund. £7.50 in a Channel Islands-domiciled fund. £2.50 per trade created as part of a rebalance |
| Exchange traded fund dealing | £1.50 per trade, plus stockbroker commission of 0.05% per order on UK, European and North American exchanges, subject to a minimum, and a £9.50 custodian settlement fee per trade |
| Foreign exchange | 0.20% on currency conversions |
| Payment out | £13.50 per payment, excluding any intermediary bank charges |
| Non-sterling withdrawals | Possible, but incur two FX transaction costs |
Table: Novia Global dealing and other charges from the 2026 schedule applying to Cameron James clients.
What that looks like in practice
| Pension value | Platform charge | Custody | SIPP fee | Total a year | Effective rate |
| £300k | £900 | £120 | £240 | £1,260 | 0.42% |
| £500k | £1,400 | £200 | £240 | £1,840 | 0.37% |
| £1m | £2,400 | £400 | £240 | £3,040 | 0.30% |
| £2m | £3,900 | £800 | £240 | £4,940 | 0.25% |
Table: illustrative totals while building the pension, for a fully invested account, before fund charges, dealing costs and advice fees. Money held in cash is not charged, so the actual figure will be slightly lower. Not a quote.
Once you start taking income
Drawdown adds £150 a year to the figures above. On top of that, each benefit crystallization event costs £200 and each payment out costs £13.50, so the total depends on how you take your benefits.
| Pension value | Charges while building | Drawdown charge | Total a year in drawdown | Effective rate |
| £300k | £1,260 | £150 | £1,410 | 0.47% |
| £500k | £1,840 | £150 | £1,990 | 0.40% |
| £1m | £3,040 | £150 | £3,190 | 0.32% |
| £2m | £4,940 | £150 | £5,090 | 0.25% |
Table: illustrative annual totals in drawdown, before crystallization and payment-out charges, fund charges, dealing costs and advice fees. A member taking a monthly income would add £162 a year in payment-out charges (12 at £13.50), plus £200 each time further benefits are crystallized. Not a quote.
How Novia Global compares on cost with Morningstar
Compared like for like, Morningstar is about £50 a year cheaper at £300k while you are building the pension, and the gap widens as the pension grows. Once income is being drawn, the gap widens further. Morningstar adds a single £125 income charge and nothing more, however often you draw. Novia Global adds a £150 drawdown charge, then £200 for each benefit crystallization event and £13.50 for each payment out. On annual charges alone Morningstar is cheaper in drawdown at every size, by £75 a year at £300k, before any of the Novia Global per-event charges are added. Morningstar does charge a one-off establishment fee, and Novia Global does not. Separately from charges, Morningstar pays interest on cash held in the account, at 1% below the Bank of England base rate on sterling and 0.35% below the US Federal Reserve rate on US dollars, while Novia Global pays none on its minimum 2% cash holding. Our side-by-side comparison sets out the full figures.
What Cameron James USA charges
Our fees for a UK pension transfer are £2,500 plus 0.5% of the transfer value for a defined contribution transfer, and £4,500 plus 0.5% for a defined benefit, or final salary, transfer, with a further £1,000 where more than one pension is transferred. An ongoing advice fee covers the ongoing service. We are fee-based and take no commission from any provider, which fits the Novia Global rules: advisers on the platform cannot be paid hidden commission or trail.
Want to compare total cost, not headline platform fees?
We model Novia Global and Morningstar side by side on your actual pension values, including fund and advice costs.
Taking Income From a Novia Global SIPP While Living in the US
Benefits can currently be taken from age 55, rising to 57 from 2028. For a US resident, there are two practical routes:
- Flexi-access drawdown. Take income in any amount, at any frequency. Novia Global supports automated regular drawdown, monthly, quarterly or twice yearly, which suits a US resident who needs a predictable income. Bear in mind the charges: £150 a year while drawdown is active, £200 each time benefits are crystallized, and £13.50 for each payment out, so a monthly income adds £162 a year in payment charges alone.
- Uncrystallized funds pension lump sum. Lump sums taken directly from the pension, 25% free of UK tax and 75% taxable in the UK, subject to the treaty. Phased uncrystallized funds pension lump sums are one of the approaches used where the US treatment of the tax free element is a concern.
Plan for sterling withdrawals
Your SIPP can be invested in US dollars, but withdrawals are currently paid in sterling. Novia Global plans shortly to allow benefits to be crystallized and withdrawals paid in foreign currencies, which would let you draw income in dollars. Until then, if you are spending dollars, that creates currency exposure on every payment. It is manageable, and for many clients a sterling pension is a useful counterweight to US assets and a hedge against a future return to the UK, but it needs to be built into the income plan: how often you draw, how the money is converted, and how much currency risk the portfolio carries in the years before you draw.
Why You Cannot Self-Invest a Novia Global SIPP From the US
The Novia Global terms require a formal adviser relationship to open and operate an account, and dealing instructions go through that adviser. For a US resident there is a second reason: advice to a US person generally has to come from an adviser holding SEC authorization. To our knowledge there are no compliant self-invest options for US residents in a UK SIPP. We set out the detail, including what to ask an adviser who charges a fee but does no work, in Can You Self-Invest in a Novia Global SIPP?. The same applies to the Morningstar International SIPP, which we cover in Can You Self-Invest in a Morningstar International SIPP?. Cameron James USA advisers hold individual SEC authorization, which is what allows us to advise US residents on the pension and the investments inside it.
Novia Global or Morningstar Wealth International?
These are the two integrated SIPP and platform providers we use most for US residents. Both are adviser-led, fee-based and institutionally backed, and on the pension alone the two are closer on cost than most people expect. The differences that decide the answer are about everything other than the pension.
| For a US resident | Novia Global | Morningstar Wealth International |
| Interest on cash | None paid, on a minimum 2% cash holding | Paid: Bank of England base rate less 1% on sterling, US Federal Reserve rate less 0.35% on US dollars |
| US-domiciled funds | Not accepted | Supported through the US Taxpayer Service |
| Non-pension account for US persons | General Investment Account not available to US persons | General Investment Account and ISA available on the US Taxpayer Service |
| Annual US tax report | No | Yes, for each ISA or investment account |
| Custodian | BNY Mellon Pershing (Channel Islands) | Northern Trust (Channel Islands) |
Table: where the two platforms differ for a US resident.
In short: for most US residents Morningstar is our preferred option. It pays interest on cash, it gives access to US-domiciled funds, which makes it the only option of the two for anyone concerned about PFIC, and it can hold ISAs, UK funds or cash to invest outside the pension on a PFIC-compliant basis. Novia Global remains a sound choice for a pension-only plan where none of those points apply. Read our Morningstar International SIPP review for US residents, the full Novia Global vs Morningstar Wealth International comparison, or see where both sit among every provider that accepts US residents in our 2026 shortlist.
How Cameron James USA Works With a Novia Global SIPP
- Review. We look at every UK pension you hold, what each one allows, and any UK investments outside the pension.
- Structure. We recommend where each pot should live: Novia Global, Morningstar, or staying put, with written reasons and full costs.
- Transfer. We handle the transfer paperwork with the ceding schemes and Novia Global, including defined benefit transfers where appropriate.
- Portfolio. We build and manage the investment strategy inside the SIPP, with the currency position planned from the start.
- Ongoing. Twice-yearly planning meetings, cash flow modelling, drawdown planning and coordination with your US CPA or Enrolled Agent, all within the ongoing advice fee.
Jonathan Laws, ACA Ch.FCSI
Senior Independent Financial Adviser, Cameron James
“Most US residents who come to us about Novia Global are asking the wrong first question. They ask whether Novia will accept them. It will. The better question is where everything else they own should live, because the SIPP is the part that is already protected and the ISA is not. Get the whole structure right and the Novia Global SIPP is one of the cleanest, lowest-cost pension homes a US resident can have. Put it in without looking at the rest and you solve one problem while leaving the expensive one in place.”
Frequently Asked Questions
Is the Novia Global SIPP a good option for US residents?
It is a sound, transparent, low-cost option that accepts US persons by design, but it is not our first choice for most US residents. Novia Global pays no interest on cash and does not accept US-domiciled funds, so for anyone concerned about PFIC, Morningstar Wealth International is the only option of the two. Novia Global suits a pension-only plan where neither point matters.
Is Novia Global the best SIPP for US residents?
For most US residents, no. In our view the Morningstar International SIPP is the better choice: it pays interest on cash, which Novia Global does not, and it gives access to US-domiciled funds, which makes it the only option of the two for anyone concerned about PFIC. Novia Global remains a sound choice for a pension-only plan where neither point matters.
Can a US resident open a Novia Global SIPP?
Yes. The Novia Global SIPP accepts non-UK residents, including US persons, provided the account is opened and managed through a regulated adviser permitted to advise them. For a US resident, that means an adviser with SEC authorization. The adviser requirement is not optional, and it is the part of the structure that keeps the arrangement compliant on the US side.
Can I transfer my UK pension to Novia Global from the US?
Yes. Personal pensions, SIPPs and most workplace defined contribution pensions can be transferred while you live in the US, through an SEC-authorized adviser. Defined benefit, or final salary, schemes with a transfer value over £30k require advice from a Pension Transfer Specialist first. Timescales depend mainly on the ceding scheme.
Can a US citizen hold a Novia Global SIPP?
Yes, into the SIPP itself. The Novia Global General Investment Account is not available to US persons, so any non-pension investments need a separate, PFIC-compliant home. For most US-connected clients that means the Morningstar US Taxpayer Service alongside the Novia Global pension, or consolidating everything with Morningstar.
Do PFIC rules apply to funds in a Novia Global SIPP?
PFIC tax is generally not expected on holdings inside the pension during accumulation. A reporting exception applies under the section 1298(f) regulations to PFIC interests held through a treaty-recognized foreign pension fund, and the SIPP is recognized as a pension under the US-UK tax treaty. Reporting may still apply in some circumstances. PFIC is squarely relevant to investments held outside the pension, such as an ISA or general investment account.
Can I hold US-domiciled exchange traded funds in a Novia Global SIPP?
No. Novia Global does not accept US-domiciled funds onto its platform. US equity exposure is held through UK or Ireland-domiciled funds, which is not expected to be a PFIC tax problem inside the SIPP. If you want US-domiciled funds, the Morningstar Wealth International US Taxpayer Service supports them.
What does a Novia Global SIPP cost?
A fixed SIPP service charge of £60 a quarter, £240 a year, with no set-up fee, a tiered platform charge of 0.30% on the first £300k stepping down to 0.25%, 0.15% and 0.10% above £2.5m, and a custodian charge of 0.04%. Neither applies to cash. Taking benefits adds a £150 a year drawdown charge, £200 per benefit crystallization event and £13.50 per payment out. Transferring out costs £250 to a UK pension or £1,000 to an overseas pension. Fund and advice costs are extra. Charges are subject to change on notice.
Can I be paid in US dollars?
Withdrawals are processed in sterling. A non-sterling withdrawal is possible but incurs two foreign exchange transaction costs, so most clients draw in sterling and convert on receipt, with the timing and cost built into their income plan. Your portfolio inside the SIPP can still be invested in US dollars.
Is the 25% tax free lump sum tax free in the US?
Not automatically. It is free of UK tax, but the general consensus among the US tax advisers we work with is that it is not tax free in the US, particularly if taken all at once, and some states such as California do not follow the treaty position. Phased withdrawals can change the outcome. Take US tax advice before taking benefits.
Can I self-invest in a Novia Global SIPP from the US?
No. The platform is adviser-led for every client, and advice to a US person generally has to come from an adviser with SEC authorization. There is no execution-only route. Be cautious of any arrangement where an adviser charges a fee but does no work, which we cover in our guide Can You Self-Invest in a Novia Global SIPP?
Is Novia Global the right home for your UK pension?
One conversation will show you where each of your UK pensions and investments should sit as a US resident, what the transfer involves, and what it costs. Fee-based, no commission.
Related Articles
These are existing Cameron James USA articles covering the questions that come up alongside this one.
Morningstar International SIPP Review for US Residents
The other integrated SIPP we use most for US residents, and where your UK ISA fits.
Can You Self-Invest in a Novia Global SIPP?
Why the platform is adviser-led, and the risks of an advised-in-name-only structure.
Can You Self-Invest in a Morningstar International SIPP?
The same question for the Morningstar International SIPP, and why the answer is also no.
Novia Global vs Morningstar Wealth International
The two platforms side by side on custody, account types, fees and access for US persons.
UK Pension and SIPP Transfer for US Residents
The full transfer guide. Options, US taxation of UK pension income, adviser regulation and the process end to end.
SIPP Providers That Accept US Residents: The 2026 Shortlist
Every provider that can compliantly hold a UK pension for a US resident, and how they differ.
The IFGL SIPP Review 2026
How a non-integrated SIPP compares with an integrated SIPP and platform.
Can a US Resident Keep a UK ISA?
The ISA rules after a move to the US, and where the PFIC exposure sits.
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.
DOMINIC JAMES MURRAY,
CEO AND FOUNDER
“Novia Global is one of the most established names in the International SIPP market, and with good reason. They were one of the first SIPPs built for non-UK residents and they do things cleanly and transparently.
Novia Global do not permit advisers to be paid any hidden fees or back-end trail commissions. Only the advice fees you transparently see and sign for on the application are permitted. Novia also lets our clients see exactly what their total costs have been since day one, which is not something every platform makes easy to find.”