How to Transfer a Transact SIPP, ISA and GIA as a US Resident: Step-by-Step Transfer Guide

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.

What Transact Has Told US-Resident Clients

Transact, operated by Integrated Financial Arrangements Ltd, has moved in two stages. In late 2025 it stopped US-connected clients from holding collective investments such as OEICs, unit trusts, and non-US ETFs inside a GIA, ISA, or offshore bond. It has since gone further and begun writing to US-resident clients requiring the SIPP, ISA, and GIA to be transferred out altogether, each letter carrying its own cut-off date. If your letter has arrived recently, the date in it supersedes anything you have read about Transact from before this year.

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

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.”

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 take the money out of the pension

If you are below the minimum pension age, currently 55 and rising to 57 from 6 April 2028, taking funds out is an unauthorized payment and the total charge to you can reach 55 percent. A scheme sanction charge may also fall on the scheme. If you are above minimum pension age the position is different but no better. The withdrawal is authorized, so the 55 percent charge does not apply, but you crystallize a taxable distribution that the IRS will assess under the treaty, you permanently lose the tax-advantaged wrapper, and you cannot put the money back. On either side of that age line, the correct route out of Transact 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. We are not aware of any compliant self-invest SIPP option currently open to US residents. The 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: Plan the disposal, because a sale is close to unavoidable

An ISA or GIA will almost never move in specie. The very holdings that create the problem, the non-US pooled funds, are the holdings a US-compliant receiving account will not accept, so in the vast majority of cases the funds are sold and the money moves across as cash. The PFIC disposal is therefore not something you can avoid. It is something you can plan. Under the default Section 1291 regime the gain is taxed at the highest marginal rate with an interest charge running back toward the purchase date. A qualified electing fund election gives a better outcome, but it depends on the fund issuing an annual PFIC information statement, which most non-US funds do not, and a late election generally requires a purging election that creates its own taxable event. A mark-to-market election is limited to marketable stock. For holdings bought years ago through a UK platform, usually none of these is realistically available, so the levers that remain are which tax year the disposal falls into, the order in which holdings are sold, and getting any historic Form 8621 reporting straight. Settle all of that with your CPA before you instruct the sale, not after it.

Step 4: Transfer to a US-compliant receiving account

Once the disposal plan is agreed, the holdings are sold and the proceeds transfer as cash. Build the resulting time out of the market into your plan, because it is a real cost and it is the reason to start early rather than at the deadline. The GIA proceeds move into a US-compliant brokerage account. The ISA needs a separate decision, and the default should be to preserve the wrapper by transferring the cash ISA to ISA with a manager that accepts non-UK residents. You cannot subscribe to an ISA while you are non-UK resident, but you can transfer an existing one, and once the wrapper is broken it cannot be rebuilt. The allowance from earlier years is gone for good. Breaking the wrapper only makes sense where a return to the UK has been genuinely ruled out, because the ISA carries no US tax benefit and does add cost and reporting. Where there is any realistic prospect of returning, the ISA structure should be retained. This is a suitability decision to be taken on your own circumstances, not a default.

Transact SIPP, ISA, and GIA at a glance

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.

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.