By Jonathan Laws, ACA, Ch.FCSI, Senior Adviser at Cameron James USA.
If you are a US citizen, a Green Card holder, or another US tax resident holding a St. James’s Place (SJP) pension, ISA, or investment account, and you have moved to the United States or already live here, your existing SJP arrangements almost certainly no longer fit your circumstances. In the case of the ISA and the general investment account, they may be actively working against you.
This guide explains why SJP products create structural problems for an expat who is a US person, what your transfer options are, and what to do next. The pension, the ISA, and the general investment account each behave differently once you cross the Atlantic, so they need to be looked at together rather than one at a time.
Key takeaways
- An SJP Partner is authorized to advise UK clients. That authorization does not follow you to the United States, so the existing adviser relationship cannot lawfully continue once you are a US resident.
- The SJP fund range is UK-domiciled. Held outside a pension wrapper, in the ISA or the GIA, those funds are typically Passive Foreign Investment Companies for US tax purposes, with Form 8621 reporting on a fund-by-fund basis.
- SJP changed its charging structure on 26 August 2025. The early withdrawal charge no longer applies to new pension and bond investments, but if you invested before that date the historical charge, up to 6 percent tapering over six years, can still apply.
- For most expats in the US, the SJP pension is best transferred to an International SIPP. A transfer between two UK-registered schemes is not a UK taxable event and is not a US distribution.
- The ISA and the GIA usually need restructuring rather than retaining. The ISA does not have to be encashed by default: it can often be transferred to a provider that accepts US-connected clients and the holdings rebuilt around non-PFIC investments.
- A QROPS is almost never the right answer for a US resident. It usually triggers the 25 percent Overseas Transfer Charge, and the US treatment brings foreign trust reporting into scope.
Do your SJP arrangements still fit your life in the US?
We will review the pension, the ISA, and the GIA together, and tell you which of them is working against you. Fee-based, no commission from providers or fund managers, individual SEC authorization.
Who Is This Guide For?
This guide is for US citizens, Green Card holders, and other US tax residents who hold products with St. James’s Place, whether a Personal Pension, an ISA, a General Investment Account, or a combination of all three. It is equally relevant if you are an expat who is soon to become a US resident and wants to understand the options before the move, or if you have already relocated and are trying to work out what to do with the SJP arrangements you left behind.
The distinction that matters is not your passport but your US tax status. Platform restrictions and US reporting obligations attach to whether you are a US person for tax purposes, not to your mailing address.
What Products Does SJP Offer?
St. James’s Place is one of the largest wealth management businesses in the UK, with an extensive Partner network and a very large client base. Three products are relevant here: the SJP Personal Pension, the SJP ISA, and the SJP General Investment Account.
The Personal Pension is a defined contribution arrangement. Contributions attract UK tax relief, the fund grows inside a pension wrapper, and benefits are taken at retirement through a combination of tax-free cash and income drawdown. The ISA is a UK Individual Savings Account, growing free of UK income tax and capital gains tax, with withdrawals free of UK tax for UK residents. The General Investment Account is a standard taxable account holding SJP-managed funds outside any tax wrapper.
All three work well in a UK context. All three create significant problems the moment you become a US resident, and for an expat who is a US person the problems are often more severe than for other non-UK residents, because of how US tax law treats UK-domiciled pooled investment funds.
The Core Problem: SJP Is Built for UK Residents
The SJP business model is designed around UK-based clients. The Partner network is authorized for UK advice, the fund range is UK-domiciled, the platform is structured around UK tax rules, and the client servicing assumes you live in the UK. When you become a US resident, several things break down at once.
Regulatory authority does not follow you to the United States
SJP Partners are authorized and regulated for UK advice. That authorization does not extend to providing ongoing investment advice to a US resident, because advising a US resident generally requires SEC or state-level authorization. The practical consequence is that the existing adviser relationship cannot lawfully continue, which leaves your pension, your ISA, and your investment account without a qualified adviser who can legally review them, restructure them, or plan around your new US tax position. You can check the authorization of any US adviser on the SEC Investment Adviser Public Disclosure database.
The fund range creates PFIC exposure
The SJP platform is built around the SJP fund range: UK-domiciled funds, reported in sterling, structured primarily with UK tax residents in mind. For a US person, UK-domiciled pooled investment funds held outside a qualifying pension wrapper are typically classified as Passive Foreign Investment Companies. PFIC taxation is punitive by design and involves Form 8621 reporting, generally on a separate form for each fund held. Tax rates and interest charges can substantially erode returns. This is not a theoretical risk for a US person holding SJP ISA or GIA funds. It is the default outcome unless the holding is restructured. We have set out how this plays out in practice in our guide to PFIC restrictions for US-connected investors.
Currency risk
SJP products are denominated in sterling. If you live in the United States and you draw income or make withdrawals, every transaction requires conversion into US dollars. Movements between the pound and the dollar can meaningfully affect your real financial position over time, and that risk is entirely unhedged in a sterling-only structure.
Exit charges
The SJP charging structure changed on 26 August 2025. For pension and bond money invested from that date, the early withdrawal charge has been removed. If you invested before 26 August 2025, the historical early withdrawal charge can still apply: up to 6 percent in the first year, tapering by roughly one percentage point a year across a six-year period, and any top-up restarts the clock on that portion. Note that the early withdrawal charge applied to pensions and investment bonds rather than to ISAs and unit trusts. Before proceeding, obtain a current statement from SJP confirming your fund value and any charge that applies to you.
Which SJP exit charge regime applies to you
| When you invested | Early withdrawal charge | What to do |
|---|---|---|
| On or after 26 August 2025 | None. The charge was removed for new pension and bond investments. | No exit penalty to plan around. Transfer timing is driven by strategy, not by charges. |
| Before 26 August 2025 | Historical charge can still apply: up to 6 percent in year one, tapering across six years. | Ask SJP in writing for your fund value and the exact charge and end date before you decide when to move. |
| A top-up before 26 August 2025 | The clock restarts on that portion of the money, so different tranches can end at different times. | Request a breakdown by tranche. Partial transfers can sometimes avoid a charge on the older money. |
| ISA and unit trust money | The early withdrawal charge did not apply to these wrappers. | The decision here is about PFIC exposure and US tax, not about exit penalties. |
SJP Pension, ISA, and GIA for Expats in the US: At a Glance
The table below summarizes how each SJP product behaves once you become a US resident, and the route that is most often appropriate.
| Product | Core problem as a US person | Contributions | Typical route |
|---|---|---|---|
| SJP Personal Pension | No adviser is authorized to advise you, and the funds are sterling-only and UK-domiciled. PFIC does not bite inside the wrapper. | Limited. Up to 3,600 pounds gross for five tax years after the year you left the UK. | Transfer to an International SIPP. |
| SJP ISA | The US does not recognize the ISA shelter, and the underlying funds are typically PFICs. | None. ISA subscriptions require UK residency. | Review. Often transfer to a US-friendly ISA provider and rebuild the holdings, or encash and restructure. |
| SJP General Investment Account | PFIC exposure on UK-domiciled funds, and no UK tax wrapper to preserve. | Not applicable. | Usually encash and reinvest in a structure suited to a US taxpayer. |
Tax treatment depends on your specific circumstances and on the US-UK Double Taxation Convention. The summary above is general and is not a substitute for personal advice. Tax laws are complex and vary by individual circumstance.
Your SJP Personal Pension as an Expat in the US
What changes when you become a US resident
None of the underlying pension mechanics change immediately, but the planning picture changes significantly. You need an adviser with SEC authorization. The treatment of your pension under the US-UK Double Taxation Convention needs to be understood and implemented correctly. And the investment strategy should be reviewed in light of US dollar currency exposure, and of PFIC considerations on anything you hold outside the pension wrapper.
Contributions after becoming a US resident
UK pension contributions attract tax relief only on UK earnings subject to UK income tax. If you no longer have UK earnings, you may still contribute up to 3,600 pounds gross per year for the five tax years after the tax year in which you left the UK, receiving basic rate relief at source, provided you were a UK resident when you joined the scheme. This is set out in the HMRC Pensions Tax Manual. Beyond that window, contributions are not eligible for UK tax relief without UK earnings, and most providers will not accept them.
Transferring to an International SIPP
For most expats in the US, transferring an SJP Personal Pension to an International SIPP is the appropriate course of action. An International SIPP is a UK-registered pension arrangement designed to accommodate clients who do not live in the UK, including US persons. The main advantages are:
- Broader investment choice: globally diversified funds, ETFs, and other assets suited to a US-resident investor, without PFIC classification, because the holdings sit inside the pension wrapper.
- US dollar payment capability, which reduces ongoing currency conversion cost and better reflects where you actually spend.
- Access to an adviser who holds SEC authorization as well as the permissions needed to advise on UK pension arrangements.
- Treaty-aligned withdrawals structured around the US-UK Double Taxation Convention, potentially enabling gross payment under an NT code, with US tax applied where you live.
Cameron James USA reviews the market of International SIPP providers in depth. The right provider depends on your portfolio size, your drawdown plans, and your beneficiary structure. Our fee schedule is published in full on our Our Cost page. The value of investments can fall as well as rise, and past performance is not a guide to future results.
Key point
A transfer between two UK-registered pension schemes is not a taxable event under UK rules, and it is not treated as a distribution for US tax purposes. No UK income tax or capital gains tax arises on the transfer itself, provided both schemes are registered with HMRC.
What the transfer process looks like
Your adviser obtains a transfer value from SJP. The receiving SIPP provider is confirmed and your application is submitted. SJP processes the transfer, typically over four to twelve weeks. Your funds are then invested in the new SIPP in line with your agreed strategy. The transfer is processed in cash, so there is a brief period out of the market, and your adviser should help you plan the timing rather than leave it to chance.
Why QROPS is rarely the right answer for a US resident
A Qualifying Recognised Overseas Pension Scheme is a pension structure held outside the UK that meets HMRC criteria to receive a UK pension transfer. For a US resident, a QROPS is almost never the right answer. Transferring to a QROPS based in a different country from the one you live in triggers a 25 percent Overseas Transfer Charge on the transfer value, and because a US resident is rarely resident in a QROPS jurisdiction such as Malta or Gibraltar, that charge almost always applies.
There is a second problem, and it is genuinely unsettled rather than clear-cut. The prevailing view among cross-border tax practitioners is that the IRS is likely to treat a QROPS as a foreign trust for US tax purposes, which would bring Form 3520 and, in many cases, Form 3520-A reporting into play, with severe penalties for errors regardless of whether any tax was actually due. The IRS has not published a definitive general ruling settling the point, so it should be treated as a live risk to be advised on rather than as a settled rule. Either way, for nearly all US-resident clients the International SIPP is the appropriate route and a QROPS is not.
Your SJP ISA as an Expat in the US
You cannot keep contributing
You cannot make new contributions to an ISA once you become a non-UK resident, because ISA eligibility requires UK residency. The day you become non-UK resident, your ability to subscribe to any ISA, including your SJP ISA, ends. GOV.UK is explicit that you must tell your ISA provider as soon as you stop being a UK resident, that the ISA can stay open, and that it continues to receive UK tax relief on the money and investments held inside it. Check your standing orders and stop them, because an accidental subscription creates a problem that has to be unwound.
The tax advantage does not follow you, and the PFIC risk does
The UK ISA exemption exists only inside UK tax law. The United States does not recognize the ISA as a tax-exempt structure, which means income and gains inside the wrapper are generally reportable and taxable on your US return. More significantly, the funds held within an SJP ISA are typically UK-domiciled pooled investment vehicles, which for a US person are usually PFICs.
Holding PFICs triggers Form 8621 filing and, absent elections made early, can result in some of the most punitive treatment in the US tax code, including tax on gains treated as though realized across the holding period, charged at the highest marginal rate, plus an interest charge. For a US person, an SJP ISA in its current form is rarely a wrapper worth preserving as it stands. That is not the same as saying the wrapper itself is worthless, which is the distinction most guides get wrong.
Your options as a US resident
There are four, not three, and the fourth is the one most often overlooked.
- Leave it in place. You accept that you cannot contribute, that the UK exemption gives you no US benefit, and that the PFIC exposure continues to accrue and compounds in complexity every year it is not addressed. This is rarely the right answer, but it is the default answer if you do nothing.
- Transfer to another UK ISA provider and change nothing else. This moves the platform but resolves neither the PFIC exposure nor the absence of a US-authorized adviser. It is motion rather than progress.
- Encash it, accepting the applicable tax treatment on the funds released, and redirect the proceeds into a US-compliant structure that avoids PFIC classification entirely. This removes the most risk, and for many people it is the right call.
- Transfer the ISA to a provider that accepts US-connected clients, keep the wrapper, and rebuild the holdings. Using the formal ISA transfer process, and investing through US-compatible holdings rather than UK or EU pooled funds, removes the PFIC problem without surrendering the ISA. This matters if there is any realistic chance you return to the UK, because the wrapper is valuable again the moment you are a UK resident, and it cannot be recreated once it is gone. We set out the mechanics in our guide to whether a US resident can keep a UK ISA.
Which of these is right depends on the size of the ISA, the unrealized gain inside it, your likelihood of returning to the UK, and your wider position. A Cameron James USA adviser will review the ISA alongside the pension and anything else you hold, and will work with your US tax preparer on any PFIC elections that could reduce the cost of unwinding the position.
Your SJP General Investment Account as an Expat in the US
An SJP General Investment Account remains invested, but the same adviser authorization problem applies, because an SJP Partner is not authorized to provide ongoing advice to a US resident. The investments sit outside any UK tax wrapper, so the PFIC exposure described above applies here in full. And because a GIA has no UK tax shelter to preserve in the first place, it is usually the arrangement that most clearly needs restructuring once you become a US resident.
Encashing the GIA and reinvesting in a US-compliant structure is often the most straightforward solution. The tax consequences of encashing depend on the gains inside the account and on the applicable double taxation treatment, so coordinated advice across UK and US rules is essential before any action is taken. Your Cameron James USA adviser will work directly with your US tax preparer on the timing and the structuring of the disposal, because the sequence matters as much as the decision.
Double Taxation and Your SJP Pension
The US-UK Double Taxation Convention determines how your UK pension income is taxed once you are a US resident. In most cases it provides that pension income is taxable only where you live, and not also in the UK. To implement that, you typically need to apply to HMRC for an NT, or No Tax, code, which instructs your pension provider to pay your pension gross without UK withholding. Without it, UK tax may be withheld at source regardless of your US residence, leaving you to reclaim it separately, which is slow and avoidable.
Why Independent Advice Matters
SJP is a restricted advice business. Its Partners recommend from the SJP fund range and are not obliged to consider whether a different provider or a different investment structure would serve you better. That is a structural feature of the SJP model rather than a criticism of any individual Partner. But it means that even setting aside the regulatory point, an SJP Partner cannot tell you that the right answer for you as a US person sits outside SJP entirely. And in any case, that Partner is not authorized to advise a US resident at all.
Cameron James USA operates on a whole-of-market basis for US-resident clients. Our advisers hold no product ties, receive no commission from providers or fund managers, and are not restricted to any platform. We assess the market of appropriate providers and structures and recommend based on your circumstances as a US person, and we publish what we charge.
Get an Independent View of Your SJP Arrangements
Pension, ISA, GIA, or all three. We look at them together, coordinated across your UK and US tax position, and we are not restricted to any one fund range. Fee-based, no commission from providers or fund managers, individual SEC authorization.
Frequently Asked Questions
Can SJP advise me now that I am a US resident?
In most cases, no. SJP Partners hold authorization for UK advice, which does not extend to providing ongoing advice to a US resident on a pension, an ISA, or an investment account. You need an adviser who holds SEC authorization.
I am a British expat who moved to the US. Does any of this change if I am not a US citizen?
Not materially. What matters is whether you are a US person for tax purposes, which includes Green Card holders and anyone who meets the substantial presence test, not only US citizens. If you are a US tax resident, the adviser authorization problem and the PFIC exposure both apply to you in the same way.
Will I pay tax when transferring my SJP pension to an International SIPP?
A transfer between two UK-registered pension schemes is not a taxable event under UK rules, and it is not treated as a distribution for US tax purposes. No UK income tax or capital gains tax arises on the transfer itself, provided both schemes are registered with HMRC.
Can I still contribute to my SJP ISA as a US resident?
No. ISA eligibility requires UK residency. Once you become non-UK resident you cannot subscribe to any ISA. The existing ISA remains open and continues to shelter the holdings inside it from UK tax, but it is frozen to new money, and it does not shelter you from US tax.
Do PFIC rules apply to my SJP ISA or GIA?
In most cases, yes. UK-domiciled pooled investment funds held outside a qualifying UK pension wrapper are typically classified as PFICs for US tax purposes, which captures most SJP ISA and GIA holdings. This is the main reason US residents are generally advised to restructure these accounts rather than simply retain them. It does not apply to funds held inside the SJP pension wrapper, which is treated differently under the US-UK Double Taxation Convention.
Can I still contribute to my SJP pension as a US resident?
Only within limits. UK pension contributions attract tax relief on UK earnings subject to UK income tax. If you no longer have UK earnings, you may contribute up to 3,600 pounds gross per year for the five tax years after the tax year in which you left the UK, provided you were a UK resident when you joined the scheme. Beyond that, contributions are generally not eligible for UK tax relief.
Does SJP still charge an exit fee if I transfer away?
It depends on when you invested. SJP changed its charging structure on 26 August 2025, and pension and bond money invested from that date is not subject to an early withdrawal charge. If you invested before then, the historical charge of up to 6 percent, tapering across six years, may still apply, and a top-up restarts the clock on that portion. Obtain a current statement from SJP confirming your fund value and any applicable charge before deciding when to transfer.
How long does it take to transfer away from SJP?
Once your adviser obtains a transfer value from SJP and submits the application, SJP typically processes the transfer over four to twelve weeks. The transfer is processed in cash, so there is a short period out of the market, which your adviser will help you plan around.
Should I use a QROPS instead of an International SIPP?
For a US resident, almost never. Most QROPS transfers from a US resident trigger the 25 percent Overseas Transfer Charge, and the likely US treatment of a QROPS as a foreign trust brings Form 3520 and Form 3520-A reporting into scope. An International SIPP avoids both problems.
Related Articles
If you are an expat reviewing UK arrangements from the United States, these are the pieces most readers of this article go to next.
Can a US Resident Keep a UK ISA? Rules, Restrictions and Next Steps
The full ISA position, including the transfer route that lets you keep the wrapper and fix the holdings.
Fidelity PFIC Restrictions: What US-Connected Persons Need to Know
How PFIC exposure plays out in practice, and why selling the funds does not erase the reporting history.
UK Pension and SIPP Transfer for US Residents: The Complete Guide
The pillar guide to moving a UK pension into an International SIPP as a US person, end to end.
Bestinvest Is Closing Accounts for US Residents
A worked example of a UK platform telling US-connected clients to leave, and what the letter actually means.
Understanding the Beacon Global Advisor Network (BGAN) Model
How individual SEC authorization works, and who you are legally contracting with in the United States.
Disclaimer and Disclosures
This article is for informational purposes only and does not constitute financial, tax, or legal advice. Always consult a qualified financial adviser before making decisions about your pension or your wider financial planning arrangements. Tax laws are complex and vary by individual circumstance. Cameron James USA does not offer tax advice.
This article is written for US citizens, Green Card holders, and other US tax residents holding UK pension, ISA, and investment products, and has no connection to advice regulated outside the United States. St. James’s Place product information referenced here reflects publicly available product literature and the announced St. James’s Place charging structure change effective 26 August 2025, together with Cameron James USA client-facing experience of SJP pension, ISA, and GIA products. References to St. James’s Place are for identification only and are not allegations of wrongdoing.
Advisory Services Disclosure. Advisory services in the United States are offered and provided through Beacon Global Advisor Network, LLC, a registered investment adviser with the US Securities and Exchange Commission (CRD 288833). Registration as an investment adviser does not imply a certain level of skill or education, and does not imply that any regulatory authority has passed upon the firm or its advisers. Beacon Global Advisor Network, LLC and Cameron James USA are not affiliated. Cameron James USA is a marketing name and is not itself SEC-registered. Individual advisers hold SEC authorization as Investment Adviser Representatives of Beacon Global Advisor Network, LLC.
Jonathan Laws, ACA Ch.FCSI
Senior Independent Financial Adviser, Cameron James
“The hardest message to deliver to a new client who has moved to the United States is that the SJP adviser they trusted for years simply cannot follow them across the border. It is nothing personal and it is no reflection on that adviser. It is regulation. An SJP Partner is authorized for UK advice, and the moment you become a US person, that authorization no longer reaches you.
My advice is to treat the move to the United States as the trigger for a full review, not as an afterthought. Look at the pension, the ISA, and the GIA together, because each one behaves differently once you are a US person, and the ISA and the GIA in particular carry PFIC exposure that gets more expensive to unwind the longer it is left. Work with an adviser who actually holds SEC authorization, and who can coordinate the UK position and the US position inside one plan rather than two.”