The Cameron James USA Ongoing Advice Service

If you are a US citizen or green card holder living outside the US, or a US resident holding assets you accumulated somewhere else, your financial life is being assessed by two tax systems at the same time. That single fact shapes everything about how advice needs to work for you.

Most advice relationships are not built for it. A US adviser will usually be excellent on the US side and blind to the foreign pension. A local adviser abroad will often be competent locally and either unaware of, or unwilling to deal with, the US reporting that follows. Neither is acting badly. Each is answering half the question, and you are the one left holding both halves.

This page sets out what our ongoing service actually involves, so you can compare it directly against what you have now.

What Being US Connected Changes About the Advice Process

The US taxes its citizens and green card holders on worldwide income regardless of where they live. That one rule creates a chain of consequences a single jurisdiction adviser is not set up to handle:

• Reporting obligations continue wherever you live, including FBAR filing, FATCA reporting and Form 8938 where the thresholds are met.
• Many non-US pooled funds are treated as passive foreign investment companies, which carries punitive tax treatment and heavy reporting when held in the wrong place.
• Foreign pensions can be treated very differently by the two systems, so the timing and structure of a withdrawal can matter as much as the amount.
• A large number of investment platforms and providers on both sides now decline US connected clients outright, which narrows the practical options.
• States apply their own rules and, in general, do not follow federal treaty positions.

Ongoing advice for a US connected client therefore has to be a continuous process rather than a one-off recommendation. The facts change, the residence position changes, and both tax systems keep moving.

Every Account You Hold, on Both Sides

Holistic planning is an easy phrase to write and a harder one to deliver. For a US connected client it means the plan accounts for the US accounts and the non-US accounts together, including the ones we have no involvement in. Planning around half a balance sheet is guessing.

On the US side

401(k) plans, including plans left with former employers that nobody has looked at since you changed job or left the country.

Traditional, Roth, rollover, SEP and SIMPLE IRAs, and the question of whether Roth conversions make sense given where you are resident and what your income looks like in a given year.

• 529 college savings plans, which can behave very differently once the account owner or the beneficiary is living outside the US, and where a state tax benefit claimed earlier may come back into question.
• Health savings accounts, which are efficient while you are in the US and are frequently not recognized as tax-privileged by the country you move to, so growth inside them may simply be taxable there.
• Taxable brokerage accounts, and employer equity including restricted stock units, options and share purchase plans.
• Social Security entitlement, and how it interacts with any foreign state pension you have built up.

On the non-US side

UK pensions in all their forms: workplace defined contribution schemes, personal pensions, SIPPs, International SIPPs and deferred defined benefit entitlements.

Overseas pensions, including QROPS, international pension plans and schemes built up in previous countries of employment.

ISAs, General Investment Accounts and other local wrappers, which is where PFIC exposure genuinely arises and where it needs looking at.

• Legacy offshore products sold to you before you were US connected, or before the seller established that you were. These are worth identifying early, because the reporting consequences are rarely what the original adviser described.
• Cash held across more than one currency, and property on either side with any associated mortgage.

The accounts that cause the most trouble are rarely the largest ones. They are the HSA that quietly stopped being efficient when you moved, the 529 opened for a child who now intends to study abroad, the old 401(k) still sitting in a default fund, and the ISA nobody told you was a reporting problem. Those are the items an ongoing relationship surfaces and a one-off recommendation does not.

We do not need to manage an account in order to plan around it. Where something is best left exactly where it is, we will tell you so.

Two Forward Planning Meetings a Year

Every ongoing client has two scheduled meetings a year, approximately six months apart. We call them forward planning meetings rather than reviews, and the distinction is deliberate. A review looks backwards at what the portfolio has done. Forward planning looks at the next six to twenty-four months and asks what is coming, what has to be decided, and what should be in place before it arrives.

A typical agenda covers:

• Changes in your circumstances, including employment, family, health, and citizenship or visa status.
• Residence and days spent in each country, and whether you are moving toward or away from a change in tax status on either side.
• Income, expenditure, and how both have moved against the assumptions in your plan.
• Upcoming liquidity needs such as a property purchase, college costs, a business sale or supporting family.
• Contributions and withdrawals, and the order in which money should be drawn from which account.
• Currency exposure relative to where you actually spend.
• Year end actions in both systems, and the allowances or elections that will otherwise be lost.
• Beneficiary designations, expression of wish forms, wills, and anything that has drifted out of date.
• Portfolio positioning, risk, and the reporting status of the underlying holdings.

Why two meetings rather than one

A single annual meeting works reasonably well when there is one tax year and one set of deadlines. It does not work when there are two. The US tax year runs to 31 December while the UK tax year runs to 5 April, so one meeting a year will always sit on the wrong side of one of them. Estimated payments, elections, contribution deadlines and gain harvesting decisions do not wait for a convenient date.

Between meetings

The two scheduled meetings are a floor rather than a ceiling. If you are offered a role in another country, inherit, exercise options, sell a business, or simply want to think something through, you contact your adviser directly. Ad hoc contact is part of the relationship, and you work with the same adviser throughout rather than a rotating service desk.

Cash Flow Modeling Built for Two Systems

Cash flow modeling is a year by year projection of income, expenditure, assets, liabilities, tax and inflation, running through your expected lifetime. For a US connected client it has to carry both tax treatments, because a projection that models only one side will systematically flatter the outcome.

It is also the foundation the advice itself is built on. We build these plans in Voyant, maintained with current tax rates, allowances and thresholds, so the projection reflects the rules as they stand rather than a rough approximation of them. Every recommendation we make rests on that plan. The planning comes first and any product follows from it, rather than a product being selected and a rationale assembled afterwards.

The questions it answers well include:

• Can I retire at 58 rather than 65, and where does the income come from in the years before Social Security starts?
• How much can I spend each year with a high probability of not running out?
• What is the most efficient order to draw from a 401(k), an IRA, a foreign pension and taxable accounts?
• Am I better off realizing this gain before or after I change residence?
• Do I need to take this much investment risk, or have I simply never been shown the alternative?

The model is not built once at outset and filed. It is rebuilt at each meeting from your actual position, because a plan based on what you expected three years ago is not a plan.

Currency

If your assets are largely in one currency and your spending is in another, currency is not a detail, it is one of the largest risks in your plan. We model in the currency you expect to spend in, and plan the exposure deliberately rather than leaving it to chance. It matters for tax as well, because currency movement can create taxable gain in one system on a transaction that produced no economic gain at all.

Tax Planning and the US-UK Treaty

Tax planning across two systems is mainly a coordination problem. The individual answers usually exist somewhere. What is missing is someone holding them together so a decision made sensibly on one side does not create a worse outcome on the other.

Pensions and the treaty

Where the US-UK double tax treaty applies, it addresses which country has taxing rights over pension income and provides mechanisms intended to prevent the same income being taxed twice in full. In practice the outcome depends heavily on the facts: the type of pension, your residence status, whether a payment is periodic or a lump sum, and how the withdrawal is structured and sequenced over time.

This is planning territory rather than filing territory, because in a number of cases the treatment follows from how and when income is taken, and that is a decision made in advance. Where a technical tax position is required, our approach is to amalgamate the opinions of specialist cross-border tax advisers rather than to assert a position ourselves.

PFIC, correctly scoped

The passive foreign investment company rules are one of the most misunderstood areas in this market, and the misunderstanding usually costs clients money.

Holdings inside a UK pension wrapper are generally outside PFIC reporting during accumulation. The mechanism is a reporting exception under the regulations at section 1298(f) for PFIC interests held through a foreign pension fund covered by an applicable income tax treaty. It is a conditional exception rather than a blanket exemption, and it is worth stating precisely, because the imprecise version is what causes the problem below. Where PFIC genuinely bites is outside the pension wrapper, in general investment accounts, ISAs and similar non-pension holdings.

The practical consequence is that clients are frequently told to liquidate perfectly appropriate pension holdings for a reason that does not apply, while the actual PFIC exposure sitting in a taxable account goes unaddressed. Getting this the right way round is precisely the kind of thing an ongoing relationship catches and a one-off recommendation does not.

Investment access and SEC authorization

Cameron James advisers are SEC authorized, Under our advised arrangement, qualifying US listed ETFs can be used for US connected clients across pension and non-pension wrappers, which resolves the PFIC problem at source rather than working around it.

State taxes

Federal treatment is only part of the answer. States set their own rules and generally do not adopt federal treaty positions, so an outcome that is defensible federally can be treated very differently at state level. California is the example most US connected clients encounter, and it is one of several states where the state analysis has to be run separately rather than assumed to follow the federal one. Where you are resident, and when you change that residence, can matter as much as what you do.

Estate Planning, and the Specialists We Put You in Touch With

Cross-border estates are where informal arrangements break. The estate tax position of a US citizen is very different from that of a non-US spouse, and the unlimited marital deduction does not apply in the same way where the surviving spouse is not a US citizen. A separate US-UK estate and gift tax treaty can affect the analysis where both systems have a claim. Wills drafted in one country may not deal correctly with assets in another, and beneficiary designations often quietly contradict the will entirely.

The mixed nationality household is where this bites hardest, and it is common among our clients. One spouse is a US person, the other is not, and the planning that would be obvious for either of them individually is wrong for them jointly.

We put you in touch with cross-border estate planning attorneys, CPAs and enrolled agents who work with US connected clients regularly. These are people we work alongside and know the quality of, not names from a directory. The introduction is not a handover: your adviser stays involved so the estate work, the tax filing and the financial plan are all built on the same facts, and so you are never left translating between professionals who have never spoken to each other.

A Collaborative Approach, With Your Adviser at the Center

Most failures we see in this market are not caused by bad advice. They are caused by correct advice given in isolation. A clean federal position that ignores state treatment. A sound estate structure that creates a reporting problem. A well constructed portfolio full of holdings that are toxic under PFIC.

Your CPA, your attorney, your pension trustees and any employer scheme each hold a piece of the picture. Our role is to hold all of it and make sure the pieces agree with one another. Most clients keep the professionals they already trust, and we work alongside them.

Lifestyle Financial Planning, Not Product Selection

Every meaningful conversation starts with what you want your life to look like. Money is the constraint on that life, not the objective. When do you want to stop working, or reduce? Which country do you intend to be in when you do, and how certain are you? Who do you need to look after? What do you want to happen to what is left?

Structures, wrappers and portfolios come after those answers, because until you have them there is no way to judge whether any given structure is the right one.

The Same Service for Every Client

Everything set out on this page is what an ongoing client receives as standard. The two forward planning meetings, the cash flow modeling and its rebuilding at each meeting, the planning work in between, the coordination with your CPA, enrolled agent and attorney, the specialist introductions, and the ongoing management of your investments are all part of the same service.

There is no premium tier that unlocks the process described here, and no version of it reserved for the largest portfolios. If it is worth doing for one client, it is worth doing for all of them.