By Jonathan Laws, ACA, Ch.FCSI, Senior Financial Adviser at Cameron James USA.
Transfer deadline alert. Transact has begun notifying US-resident clients that it can no longer service their SIPP, ISA, or GIA, and that holdings must be transferred out by an individually assigned cut-off date. If you have received this notice, treat the date in your letter as firm and start your transfer plan now. The sections below walk through exactly how to transfer each account type.
If you are a US citizen, Green Card holder, or otherwise a US tax resident holding a Transact SIPP, ISA, or General Investment Account (GIA), you will need to transfer that account, because Transact can no longer service US residents. Transact has followed Interactive Investor, Standard Life Aberdeen, Vanguard UK, AJ Bell, Hargreaves Lansdown, and Fidelity UK in exiting the US-resident market. This guide walks through exactly how to transfer a Transact SIPP, ISA, and GIA as a US resident, in the right order, to a compliant receiving provider, without triggering unnecessary tax consequences on either side of the Atlantic.
Key takeaways
- Transact has notified US-resident clients that their SIPP, ISA, and GIA accounts must be transferred out by an individually assigned deadline.
- Transfer the SIPP first. A pension should move by a direct SIPP-to-SIPP transfer, not a cash withdrawal, to avoid triggering UK unauthorized payment charges.
- Transferring the ISA and GIA needs a separate PFIC check if they hold non-US collective funds, because an ISA has no special status for US tax purposes.
- Any adviser arranging the transfer for a US resident must hold individual SEC authorization. FCA authorization is largely irrelevant.
- Cameron James USA advisers hold individual SEC authorization and can manage the SIPP, ISA, and GIA transfers together as one coordinated process.
Received a Transact closure notice? Do not move to cash first
Our SEC authorized advisers map your SIPP, ISA, and GIA and run the transfer in the right order. Cameron James USA is fee based, takes no product commission, and every adviser holds individual SEC authorization.
Why Is Transact Closing Accounts for US Residents?
Transact, operated by Integrated Financial Arrangements Ltd, is one of the largest retail investment platforms in the UK, widely used by FCA-regulated advisers to hold client SIPPs, ISAs, GIAs, and offshore bonds. The platform has cited the growing weight of US regulatory, tax, and reporting obligations that arise from servicing US tax residents under a UK-only FCA permission.
US citizens and tax residents are subject to worldwide reporting requirements under FATCA, the Foreign Account Tax Compliance Act, and related IRS disclosure rules. Platforms and advisers serving US clients are also generally expected to register with the US Securities and Exchange Commission (SEC), or a relevant state regulator. Transact is not SEC-registered, and the FCA-only advisers who operate the platform are not either. Rather than build the compliance infrastructure this requires, Transact, like the platforms before it, has chosen to exit US-resident clients.
A Note From Jonathan Laws
How to Transfer Your Transact SIPP as a US Resident
For most affected clients, the SIPP is the account to transfer first, and the one where a wrong move is hardest to undo.
Step 1: Do not withdraw the cash
Withdrawing funds from a SIPP before the minimum pension age, currently 55 and rising to 57 from 6 April 2028, triggers significant UK tax charges, including an unauthorized payment surcharge that can take the total charge to as much as 55 percent. Taking funds outside the pension wrapper also permanently removes their tax-advantaged status. For the large majority of US residents transferring out of Transact, the correct route is a direct SIPP-to-SIPP transfer, not a withdrawal.
Step 2: Find a receiving SIPP that will accept a US resident
This is where most people hit a wall. The same pressures that led Transact to exit US-resident clients have already led most major UK SIPP providers, including Interactive Investor, Standard Life Aberdeen, Vanguard UK, AJ Bell, and Hargreaves Lansdown, to do the same. There are currently no compliant self-invest SIPP options available to US residents. The only workable route is transferring to an International SIPP, arranged and advised on by an adviser who holds individual SEC authorization.
Step 3: Instruct the transfer through an SEC-authorized adviser
The SIPP itself remains a UK pension, fully subject to UK pension rules, throughout the transfer. What changes is who advises on it and where it is held. Your adviser instructs the transfer directly with the receiving International SIPP provider, who then requests the assets from Transact on your behalf, so you are not left holding or transferring cash yourself.
Step 4: Confirm the transfer and reinvest
Once the receiving SIPP confirms the assets have arrived, in specie where possible or in cash where a fund is not transferable, your adviser rebuilds the portfolio using instruments that are appropriate for a US person going forward, which typically means avoiding a straight re-purchase of the same non-US pooled funds. Our International SIPP overview and our fully published Our Cost page show how that receiving structure and its fees work.
How to Transfer Your Transact ISA and GIA as a US Resident
Your Transact ISA and GIA are not pensions, and the transfer process, and the tax treatment, are different from the SIPP.
Step 1: Understand what you are actually transferring
The tax-free ISA wrapper is a UK concept only. As HMRC guidance on ISAs confirms, the wrapper works for UK residents, but the IRS does not recognize it, and an ISA is treated as an ordinary taxable foreign account for US tax purposes. This does not change how the transfer itself works, but it does mean the tax benefits you are used to in the UK do not carry over, so the ISA and the GIA can usually be transferred using the same process. See our guide on whether a US resident can keep a UK ISA for the detail.
Step 2: Check for PFIC exposure before you transfer
Under US tax law, most non-US mutual funds, OEICs, unit trusts, and ETFs are classified as Passive Foreign Investment Companies (PFICs). For US taxpayers, PFICs carry some of the most punitive provisions in the entire US tax code:
- Each PFIC holding must be reported to the IRS on Form 8621 every year.
- Gains and certain distributions can be taxed at the highest marginal US rate.
- An interest charge can apply to gains that built up in earlier years, backdated toward the original purchase date.
Important
Closing the account does not erase past PFIC exposure. If you have held non-US collective investments in a Transact ISA or GIA while being a US taxpayer, you may already have historic IRS reporting obligations on Form 8621. This should be reviewed with a US-qualified cross-border CPA alongside the transfer.
Step 3: Transfer to a US-compliant receiving account
Once any PFIC exposure has been flagged, the ISA and GIA holdings can be transferred, either in specie where the receiving platform accepts the same holdings, or in cash where a fund needs to be sold first. Because the ISA loses no UK tax benefit that carries value for a US taxpayer, many clients transfer the ISA into a standard taxable account structure rather than another ISA, while the GIA transfers directly across as a like-for-like brokerage account. Only those who have an intention or there is some possibility they return to the UK are best advised to retain an ISA structure.
Transact SIPP, ISA, and GIA at a glance
| Account | How it transfers | The key US tax point |
|---|---|---|
| Transact SIPP | Direct SIPP-to-SIPP transfer into an International SIPP, arranged by an SEC-authorized adviser. | Do not withdraw before minimum pension age (55, rising to 57 from 6 April 2028). PFIC rules generally do not apply to holdings inside the pension wrapper. |
| Transact ISA | Moved into an ISA or standard taxable brokerage structure, in specie where possible or in cash. | The IRS does not recognize the ISA and treats it as an ordinary taxable foreign account. Non-US funds inside it are usually PFICs (Form 8621). |
| Transact GIA | Transfers like-for-like into a US-compliant brokerage account, in specie or in cash. | There is no UK wrapper benefit to lose. Non-US pooled funds are usually PFICs and should be reviewed before the transfer. |
Who Should Arrange the Transfer For You?
This is one of the most commonly misunderstood parts of the process. Advice on the investments of a US resident, whether the SIPP, the ISA, or the GIA, must be provided by an adviser holding individual SEC authorization. An FCA-authorized adviser cannot lawfully provide ongoing, fully insured advice to a US person without also holding that authorization, other than under a very narrow incidental exemption that does not cover active marketing or solicitation of US residents. If an adviser without SEC authorization offers to manage your transfer, the advice will likely fall outside the available exemptions and outside their professional indemnity cover, and it is likely to route you into another platform with the same underlying problem, such as AJ Bell or a different UK-only wrapper that does not accept US residents at all.
What Happens If You Do Not Transfer Before Your Deadline?
If no transfer is in progress by the date in your letter, Transact is likely to restrict the account in ways consistent with how other platforms have handled the same closure process. Based on precedent set by Interactive Investor, Standard Life Aberdeen, and Vanguard UK, this typically means:
- No further contributions to the SIPP, ISA, or GIA.
- No new trades or switches, with the portfolio frozen in its current allocation.
- No incoming transfers accepted.
- Eventual forced liquidation of holdings, on the timetable of Transact rather than yours.
A forced sale removes your control over the timing and tax treatment of any disposal. Starting the process early, ideally as soon as you receive the notice, keeps that decision in your hands.
How Cameron James USA Manages the Transfer For You
Cameron James USA advisers hold individual SEC authorization, giving clients a genuinely joined-up transfer of the SIPP, ISA, and GIA together rather than three separate, disconnected processes.
- Review your Transact SIPP, ISA, and GIA and confirm your notice period and deadline.
- Instruct a compliant International SIPP-to-SIPP transfer, avoiding UK unauthorized payment charges.
- Assess PFIC exposure in the ISA and GIA before transferring, and coordinate with a US-qualified CPA on historic reporting.
- Handle the transfer paperwork with the receiving provider on your behalf.
- Rebuild a PFIC-aware portfolio using instruments appropriate for a US person once the transfer completes.
Transfer Checklist: Questions to Ask Before You Start
- Have I confirmed the exact transfer deadline in my Transact letter?
- Do I know which of my holdings, if any, are PFICs, before I initiate the transfer?
- Is my SIPP transfer being arranged as a direct SIPP-to-SIPP transfer, not a cash withdrawal?
- Is the person arranging my transfer SEC-authorized?
- Have I addressed any historic PFIC reporting with a qualified CPA, separately from the transfer itself?
Start your Transact transfer with a coordinated plan
The order you transfer in and who advises you both matter. Cameron James USA advisers hold individual SEC authorization through Beacon Global Advisor Network and move your SIPP, ISA, and GIA together as one process.
Frequently Asked Questions
How do I transfer my Transact SIPP to another provider?
You transfer a Transact SIPP by opening a receiving pension that accepts US-resident clients, typically an International SIPP, and instructing your new adviser to request a direct SIPP-to-SIPP transfer. You should not withdraw the funds yourself. Your adviser and the receiving provider handle the request with Transact directly.
Why do I need to transfer my Transact account as a US resident?
Transact has cited the growing complexity of US regulatory, tax, and reporting requirements involved in servicing US tax residents under a UK-only FCA permission, including FATCA reporting and SEC registration expectations. Transact is not SEC-registered, so it requires US-resident clients to transfer out.
Can I keep my Transact SIPP if I am a US resident?
Not under Transact. Once you are identified as a US resident, Transact will require the SIPP to be transferred out. The SIPP itself does not have to be surrendered. It can be transferred to an International SIPP advised by an SEC-authorized adviser.
What is PFIC, and why does it matter for my Transact ISA or GIA?
PFIC stands for Passive Foreign Investment Company. Most non-US mutual funds, OEICs, unit trusts, and ETFs are classified as PFICs under US tax law. US taxpayers holding PFICs face annual IRS reporting on Form 8621 and potentially punitive tax rates on gains. If you have held non-US funds in a Transact ISA or GIA as a US person, you may already have historic reporting obligations.
Is Cameron James USA authorized to advise me?
Cameron James USA advisers hold individual SEC authorization through Beacon Global Advisor Network, LLC (CRD 288833), which is the relevant regulatory permission for advising US residents on their investments, including a UK-held SIPP, ISA, or GIA.
How long does a Transact SIPP transfer take?
Transfers of this kind typically take between four and twelve weeks, depending on both the transferring and receiving providers. Starting as soon as you receive your closure notice gives you the best chance of completing the transfer comfortably ahead of your deadline.
Related Articles
This guide is part of our series on UK platform closures for US residents. If Transact is not the only account affected, these companion guides cover the other providers and the tax issues that come with them.
Interactive Investor SIPP Closing for US Residents
The same transfer-out process for an Interactive Investor SIPP, ISA, and GIA, including the January 2026 cut-off dates and the PFIC trap.
Standard Life Aberdeen SIPP Closing for US Residents
The Standard Life transfer deadline of 31 May 2026, why the recommended start date is late March, and how the SIPP-to-SIPP route works.
Vanguard UK Closed Your Account? Help for US Residents
Why Vanguard UK exits US persons entirely rather than freezing the account, and how to transfer the SIPP, ISA, or GIA compliantly.
Can a US Resident Keep a UK ISA?
Why the ISA loses its tax free status for US tax purposes, how PFIC rules apply inside it, and what to check before you move it.
UK Pension Transfer to USA: International SIPP for US Residents
How the International SIPP works, why QROPS rarely suits US residents, and how UK and US retirement planning fit together.
Disclaimer and Disclosures
This article is for informational purposes only and does not constitute financial, tax, or legal advice. Always consult a qualified and regulated financial adviser before making any decisions about your pension or investment arrangements. Tax laws are complex and vary by individual circumstance. Cameron James USA does not offer tax advice.
This article is intended for US citizens and US persons. Advisory services in the United States are offered and provided through Beacon Global Advisor Network, LLC, a registered investment adviser with the Securities and Exchange Commission. 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 licensed or registered to conduct advisory business. UK pension and platform matters are handled with FCA-authorized colleagues on the UK side of the firm.
PFIC treatment, UK pension charges, and platform positions referenced in this article reflect the understanding of Cameron James USA as at the date of publication. They are complex, depend on individual circumstances, and can change. Verify your position with a qualified US and UK adviser before initiating any transfer.
Jonathan Laws, ACA Ch.FCSI
SENIOR FINANCIAL ADVISER, CAMERON JAMES USA
“When a Transact letter lands, the instinct is to treat it as an emergency and move everything into cash as fast as possible. That is the one move I would ask you to slow down on. A rushed cash transfer out of a SIPP can create UK tax charges that were entirely avoidable, and selling pooled funds in a hurry can crystallize a PFIC problem at the worst possible moment.
The deadline in your letter is real, but you almost always have more time than it feels like on the day it arrives. The clients who come out of this best are the ones who map the SIPP, the ISA, and the GIA together, confirm what can move in specie, and let an adviser who holds individual SEC authorization run the transfer as one coordinated process rather than three separate scrambles.”