By Jonathan Laws, ACA, Ch.FCSI, Senior Independent Financial Adviser, Cameron James USA
If you hold a UK pension and now live in the United States, you are dealing with one of the most technically demanding areas of cross-border financial planning. You face two tax systems, two sets of regulators, a tax treaty that pre-dates UK pension freedoms, and a market full of advisers who understand one side of the Atlantic but rarely both.
This guide is the starting point. It covers your three realistic options, why an International SIPP is usually the right home for a defined contribution pension, why a QROPS rarely is, what changes for US tax and reporting, and what a properly run transfer looks like. Where a topic needs more depth, we link to the dedicated guide.
Cameron James USA is a fee-only firm. Cameron James USA advisers hold individual SEC authorisation, which is the permission that matters when advising a US resident. All Cameron James USA advisers are also FCA regulated in the UK. We do not charge initial advice fees on US-connected investments or US pensions.
Key Takeaways
- You cannot transfer a UK pension into a 401(k) or IRA. The realistic choices are leaving it where it is, an International SIPP or a QROPS.
- For most US residents with a defined contribution pension, an International SIPP is the right destination. It stays a UK registered pension and keeps its US-UK treaty protection.
- A QROPS is rarely suitable for a US resident. A 25% Overseas Transfer Charge will generally apply, and the US reporting burden is heavier.
- Only a handful of International SIPP providers accept US residents, and only through an adviser with US permissions. For most US residents, Morningstar Wealth International is our preferred option.
- The 25% lump sum is tax free in the UK but not reliably tax free in the US. Plan it with a cross-border tax adviser before taking it.
- Cameron James USA is fee-only, with a published hybrid transfer fee capped at £12k for DC and £15k for DB pensions.
Can You Transfer a UK Pension to a 401(k) or IRA?
No. You cannot transfer a UK pension directly into a 401(k), an IRA or any other US retirement plan. UK law only allows a pension to move to another UK registered scheme or to a Qualifying Recognised Overseas Pension Scheme (QROPS), and no US retirement plan holds QROPS status.
A transfer outside those rules is an unauthorised payment, which can trigger UK tax charges of up to 55% of the amount moved. This is not a theoretical risk: poorly advised savers have paid it. If anyone has told you a direct 401(k) or IRA rollover is possible, get a second opinion before you sign anything.
What you can do is move your pension into a structure that works for a US resident. The two candidates are an International SIPP and a QROPS, and for most US residents only one of them is appropriate. But there is a prior question: should you transfer at all? A transfer is not automatically the right answer. A properly run review starts with what you need your pension to do, and whether it can already do that where it sits.
Start With Your Retirement Goals, Not Pension Structures
An International SIPP, a QROPS or leaving things alone are all means to an end, and that end is your retirement. Before discussing products, a good adviser should be asking a different set of questions:
- When do you want to stop working, and what does that transition look like?
- Where will you live in retirement: permanently in the US, or splitting your time?
- What income will you need in the first year of retirement, and how might that change over 10 to 20 years?
- Is a spouse or partner’s retirement tied up with yours?
- What else do you have: a 401(k), an IRA, Social Security, property?
- How would a 20% fall in your portfolio affect your plans?
- Do you want to pass assets to the next generation, or spend the money yourself?
- Is there any realistic chance you move back to the UK?
These questions are not a preamble to the real advice. They are the real advice. The right structure for a 52-year-old in Texas who plans to retire at 60, split time between the US and Europe and leave an inheritance to two adult children looks very different from the right structure for a 64-year-old in New York who wants maximum income now and has no dependants.
Your Three Options as a US Resident With a UK Pension
| Option | What it means in practice | Suitability |
| Leave it where it is | The pension stays with your existing UK provider. This only works if the provider will keep serving you as a US resident, offers flexible drawdown and can pay income to a US bank account. It is more common for pensions still inside an employer scheme. | Possible if the provider supports US residents |
| Transfer to an International SIPP | The pension moves to a UK registered scheme run by an FCA-regulated SIPP provider and built for non-UK residents. It remains a UK pension, so it keeps its treaty status. | Usually the right answer for DC pensions |
| Transfer to a QROPS | The pension leaves the UK system for an overseas scheme recognised by HMRC. A 25% Overseas Transfer Charge will generally apply, and the US tax and reporting position becomes more complicated. | Rarely suitable for US residents |
What Is an International SIPP and Why Does It Suit US Residents?
An International SIPP (Self-Invested Personal Pension) is a UK registered pension scheme designed for people who built up UK pension savings and now live overseas. It is not an offshore product. It stays inside the UK pension framework, the SIPP provider is FCA regulated, and the Financial Services Compensation Scheme can protect up to £85k if the provider fails, subject to the FSCS rules.
That matters for US residents because a UK registered pension stays within the pension article of the US-UK tax treaty. There is a good chance the IRS would regard a SIPP as a foreign grantor trust, but our view is that this does not remove the treaty protection. In practice, an International SIPP is the most straightforward way to hold UK pension money as a US taxpayer, and the clearest contrast with a QROPS.
What an International SIPP can do that a legacy UK pension often cannot
- Flexible drawdown: take income in the amounts and at the times that suit you, rather than being locked into an annuity or a rigid schedule.
- Better investment choice: low-cost, globally diversified funds instead of the limited and often expensive default funds in old workplace schemes. On some platforms that includes US-domiciled funds (see the providers section below).
- US dollars: hold the pension in dollars and have income paid to a US bank account, avoiding constant currency conversion.
- Consolidation: bring pensions from several old employers into one managed account.
- Joined-up advice: an adviser with individual SEC authorisation, who is also FCA regulated, can manage the pension as part of your wider US retirement plan.
Flexible income is particularly valuable. Drawing more in high-spending years (a renovation, a big trip, a gift to children) and less in quieter ones gives you control over both your lifestyle and your annual US tax position.
Who does an International SIPP suit?
Broadly, any US resident with a defined contribution pension, meaning a pot of money rather than a guaranteed income from a final salary scheme. It is especially useful where:
- Your UK provider has restricted or closed its service to US residents
- You have several pensions with old employers and want one consolidated view
- Your pension sits in a default fund nobody is managing
- You want income in US dollars paid to a US bank account
- You want your UK pension managed alongside the rest of your US retirement planning
It can also be appropriate for a defined benefit pension, but only in specific and carefully assessed circumstances (see the DB section below).
Which International SIPP Providers Accept US Residents?
Very few International SIPP providers will accept a US resident, and those that do only accept them through an adviser with the appropriate US permissions. Self-investing from the US is not an option on these platforms: a UK platform dealing directly with a US resident, without an SEC-authorised adviser, would run into US broker-dealer rules. That is why the providers serving US residents are adviser-only.
| Provider | Structure | What matters for a US resident |
| Morningstar Wealth International | Integrated SIPP and investment platform | Can hold qualifying US-domiciled funds, so US dividends do not suffer the 15% withholding lost inside Irish and UK funds. Pays interest on cash. Custody with Northern Trust Channel Islands. Our preferred option for most US residents. |
| Novia Global | Integrated SIPP and investment platform | Fully FCA-regulated platform with competitive tiered charges (the rates available through Cameron James are lower than Novia’s standard rate card). Does not accept US-domiciled funds and pays no interest on cash. Custody with BNY Mellon Pershing Channel Islands. |
| iPensions Group, IFGL Pensions | SIPP wrapper only | Needs a separate investment platform held inside the wrapper, which adds a layer of administration and cost. |
For a typical balanced portfolio, Morningstar’s US fund access and cash interest are worth roughly 0.10% to 0.20% a year in relative cost against Novia Global, depending on how much of the portfolio is in US equities. We compare the two in detail in our Novia Global vs Morningstar guide, and set out the full list in SIPP providers that accept US residents.
PFIC and Your UK Pension
The Passive Foreign Investment Company (PFIC) rules are among the most punitive parts of the US tax code for anyone holding non-US funds. UK unit trusts, OEICs and most UK- and Ireland-domiciled ETFs are PFICs in the hands of a US taxpayer.
Inside a UK pension the position is very different. The US-UK treaty is generally understood to remove PFIC tax on holdings inside a UK registered pension such as a SIPP, although some PFIC reporting may still apply even where no tax is due. Outside the pension, in an ISA or a general investment account (the UK name for a taxable brokerage account), the PFIC rules apply in full. We explain the knock-on effects in our guides to frozen UK investment accounts and Fidelity PFIC restrictions.
This is one more reason to keep UK pension money inside a UK registered pension, rather than moving it offshore or cashing it out and reinvesting. Your tax adviser should confirm the reporting position for your own holdings.
QROPS Transfers: Why They Are Rarely Right for US Residents
A QROPS is an overseas pension scheme that HMRC recognises as able to receive UK pension transfers, most commonly based in Malta or Gibraltar. When you transfer to one, your pension leaves the UK tax and regulatory framework and moves to the jurisdiction of the receiving scheme.
QROPS were designed mainly for people emigrating permanently to a country where a local scheme offers specific advantages. For US residents they are rarely appropriate, for three reasons.
IRS Warning: QROPS, Foreign Trust Reporting and the Overseas Transfer Charge
A QROPS held by a US person is typically treated by the IRS as a foreign grantor trust that sits outside the UK pension treaty framework. That brings annual Form 3520 and Form 3520-A filings, which are complex and specialist. The penalties for getting them wrong are severe: up to 35% of unreported distributions on Form 3520, and the greater of $10k or 5% of the trust’s assets for a missed Form 3520-A.
Separately, a 25% Overseas Transfer Charge payable to HMRC will generally apply to a QROPS transfer by a US resident, because there is no US-based QROPS for the main exemption to attach to.
We explain the reporting in detail in our Form 3520 guide for QROPS members.
Once a pension has left the UK system through a QROPS, it no longer sits clearly within the treaty’s pension provisions in the way a UK registered scheme does, so the protections that reduce your US tax exposure are less clearly available.
There are narrow cases where a QROPS might be relevant to a US-connected person, usually involving dual nationality, a planned move elsewhere or complex cross-border estate planning. These need specialist legal and tax input and are the exception, not the rule. If you already hold a QROPS, it may be possible to move it back to a UK registered pension.
Red Flag: QROPS Recommendations to US Residents
If an adviser recommends a QROPS to you as a US resident without a detailed written explanation of your IRS filing position and the foreign trust implications, treat that as a serious red flag. Get a second opinion from an adviser with individual SEC authorisation.
Should You Leave Your UK Pension Where It Is?
This is a legitimate option and worth considering honestly. If your UK provider offers flexible drawdown, a sensible investment range and payment to a US bank account, and will keep serving you as a US resident, you may not need to transfer at all.
When leaving things alone makes sense
- Your provider fully supports US-resident members
- Your pension is small enough that transfer costs outweigh the benefit
- You are within two to three years of your target retirement date
- You are considering moving back to the UK in the medium term
- The scheme already gives you full flexible access inside an employer pension
When doing nothing becomes a problem
- Your provider has written to you requiring a transfer out. Several major UK providers, including Aviva, Standard Life, Vanguard UK and Interactive Investor, have restricted service to US residents. We cover the main providers individually, for example in our Fidelity transfer guide.
- Your pension is in a default fund drifting away from an appropriate level of risk
- You cannot receive income in a US bank account, or face punitive currency charges
- You hold several pensions with no consolidated view of your retirement position
- Nobody is advising you, so nobody is checking the pension still fits your plans
Provider Restriction Notices
A letter from your UK provider saying it can no longer serve you as a US resident is not a crisis, but it does need prompt action. Use the forced move to consolidate any other UK pensions and set up a properly structured International SIPP from the start. Do not rush into whichever provider will take you just to meet a deadline.
How Your UK Pension Is Taxed in the US
As a US person (a citizen, green card holder or tax resident) you are taxed on your worldwide income, and UK pension income is within scope. The detail is genuinely complicated, it depends on your own facts, and independent cross-border tax advice is needed in the majority of cases. Cameron James USA does not give tax advice. We work alongside specialist US/UK tax advisers and coordinate your planning with them. What follows is the shape of the issues, not a substitute for that advice.
The treaty in brief
Under Article 17 of the US-UK treaty, pension income paid to a US resident from a UK pension is generally taxable only in the US. To stop UK tax being deducted, you claim treaty relief on HMRC Form DT-Individual so the provider can apply an NT (no tax) code. HMRC coding does not always go right first time, so it needs monitoring.
UK government service pensions (civil service, armed forces, teachers, NHS and similar) fall under Article 19 instead and are generally taxable only in the UK, unless you are both resident in and a national of the US. If you are a US citizen, the treaty’s saving clause also limits which pension provisions you can rely on. And because the treaty pre-dates UK pension freedoms, flexible drawdown, the tax-free lump sum and death benefits are not explicitly addressed in its text.
The 25% tax-free lump sum
In the UK you can usually take up to 25% of your pension tax free. Since the Lifetime Allowance was abolished in April 2024, the total is capped by the Lump Sum Allowance, currently £268,275 unless you hold a protected higher amount.
Whether that lump sum is also tax free in the US is the most debated question in this area. The general view among the tax advisers we work with is that it is not reliably tax free in the US, particularly if taken all at once, although there are treaty arguments for taking it gradually. Some states, California in particular, do not follow the federal position. Our 25% lump sum guide sets out the arguments in full.
Drawdown income
Income drawn from the pension is reported as ordinary income on your US return, and state tax may apply depending on where you live. How much you draw, and when, matters: drawdown should be planned each year with your tax adviser, alongside Social Security, Medicare premiums and your other income.
Death benefits
From April 2027, unused UK pension funds fall within the scope of UK Inheritance Tax for the first time, a significant change for anyone with a large pension and a UK-connected estate. How inherited UK pension money is taxed in the US is a separate question for your tax adviser.
IRS and FinCEN Reporting for UK Pension Holders
As a US person with a UK pension you have annual reporting obligations to the IRS and to FinCEN, whether or not you draw any income. Penalties for missing them can be substantial.
| Obligation | What it requires |
| FBAR (FinCEN Form 114) | Required if your foreign financial accounts total more than $10k at any point in the year. UK pensions count. Filed with FinCEN, separately from your tax return, by April 15 with an automatic extension to October 15. Non-wilful penalties are inflation-adjusted and, since the Supreme Court’s 2023 Bittner decision, apply per report rather than per account. |
| Form 8938 (FATCA) | Required if your specified foreign financial assets exceed $50k at year end or $75k at any time (single), or $100k and $150k (married filing jointly). Higher thresholds apply if you live outside the US. Filed with your Form 1040. |
| Form 3520 / 3520-A | Required where a pension is treated as a foreign grantor trust outside the exemption for foreign retirement trusts, which is the usual position for a QROPS. A UK SIPP will generally fall within that exemption under Rev. Proc. 2020-17, but your tax adviser should confirm it on your facts. |
| Form 8621 (PFIC) | Mainly relevant to funds held outside a pension, such as an ISA or general investment account. Whether any reporting applies to holdings inside a SIPP should be confirmed with your tax adviser. |
| Form 1040 | UK pension income is reported as ordinary income on your federal return, with any treaty position claimed correctly. |
US-UK tax filing is a specialist discipline. Make sure your tax adviser has specific US-UK pension experience, not just general expat knowledge.
What Does a UK Pension Transfer Cost?
Fees in cross-border pension advice vary widely, and the industry has a long history of poor transparency. It is worth being direct about how this works.
The industry norm
Most expat-focused advisers charge a percentage of the pension value for the initial transfer, typically 1% to 3% and occasionally more. On a £300k pension a 2% fee is £6k; on £600k it is £12k. Ongoing fees typically sit between 0.75% and 1.5% a year.
What Cameron James USA charges
We are fee-only and take no commission. Our initial fee for a UK pension transfer is a hybrid: a fixed £2.5k for a defined contribution pension (£4.5k for defined benefit) plus 0.5% of the transfer value, with £1k added where more than one pension is involved. The total initial fee is capped at £12k for DC and £15k for DB, and the multiple pension addition never takes you above the cap.
For example, a single £800k DC pension costs £2.5k plus £4k, a total of £6.5k. At a flat 2%, the same transfer would cost £16k. We do not charge initial advice fees on US-connected investments or US pensions such as a 401(k) or IRA. Our ongoing advice fee is tiered and set out in our published fee schedule, and we compare the main charging models in UK pension transfer fees for US residents.
Total cost of ownership
When comparing advisers, ask for the total annual cost as a percentage of your pension, covering the adviser fee, SIPP and platform charges and fund costs. With a well-built International SIPP using low-cost index funds, the total typically sits between 1% and 1.5% a year. A good adviser will show you the long-term effect of different cost levels on your retirement income.
The Transfer Process: Step by Step
| Stage | What happens |
| 1. Discovery | A full review of your existing pensions (type, value, provider, features and any guaranteed benefits) and your wider position: other assets, income needs, US tax position and retirement goals. |
| 2. Suitability analysis | A written report on whether a transfer is in your interests, which structure fits and how the money should be invested. For DB pensions with safeguarded benefits worth £30k or more, UK law also requires advice from an FCA-authorised pension transfer specialist before the scheme will release the transfer. |
| 3. Provider selection | If a transfer is suitable, a recommendation of a specific International SIPP provider based on pension size, currency, investment needs and cost. |
| 4. Account opening | The SIPP is opened, with standard identity, address and source of funds checks. |
| 5. Transfer | Transfer requests go to your existing provider(s). DC transfers typically take 4 to 12 weeks; DB transfers can take 3 to 6 months or longer. |
| 6. Investment | The money is invested in line with the strategy agreed in advance. |
| 7. Ongoing planning | Regular reviews, drawdown planning, rebalancing and coordination with your US tax filing. The relationship does not end when the transfer completes. |
One practical point from our own experience. UK pension schemes are generally far more comfortable releasing a transfer when the adviser involved is on the FCA register, even though FCA regulation is not technically what governs advice to a US resident. Anecdotally, that means the transfers we complete are often much quicker than those handled by advisers who are not FCA regulated, with fewer queries from the ceding scheme along the way.
Defined Benefit and Final Salary Pensions
A defined benefit (DB) or final salary pension pays a guaranteed income, usually with inflation-linked increases and a spouse’s pension. Transferring swaps that guarantee for a cash equivalent transfer value (CETV) invested in a SIPP, and from then on your income depends on investment returns. Those guarantees are valuable and expensive to replicate, so the bar for a DB transfer is high.
Legal Requirement: Specialist Advice Is Mandatory
If your DB pension (or any pension with safeguarded benefits) has a transfer value of £30k or more, UK law requires you to take advice from an FCA-authorised pension transfer specialist before the scheme can release it. As a US resident, you also need advice from an adviser with US permissions on the receiving SIPP and the investments in it.
When a DB transfer might make sense
- Your health means a materially shorter life expectancy than the scheme assumes
- You have ample guaranteed income elsewhere and do not rely on this pension for essentials
- Flexible income or passing money to your family matters more to you than a fixed income
- The CETV is high relative to the income you would give up
When it usually does not
- You rely on this income for essential spending and value certainty
- You are in good health and the scheme is well funded
- The CETV is poor value relative to the income given up
Every DB pension and every situation is different. Our final salary pension transfer guide for US residents covers the analysis in full.
Ready to Take Control of Your UK Pension?
Book a free, no-obligation consultation with a Cameron James USA adviser. You will come away with a clear picture of your options and an honest view of whether a transfer makes sense for you.
Why Adviser Regulation Matters for US Residents
Advising a US resident on investments, including pension investments and drawdown, generally requires the adviser to be registered as an investment adviser in the US or to advise through a registered investment adviser. UK FCA authorisation is not the relevant permission for a US resident, however long an adviser has held it.
There is a narrow foreign private adviser exemption, but it comes with strict conditions, including not holding out to the public in the US as an investment adviser. A firm running US-facing marketing while relying on it is taking a serious regulatory risk, and its clients may find its professional indemnity insurance does not respond if something goes wrong. We explain this in can a UK adviser give FCA regulated advice to a US resident?
Our Regulatory Standing
Cameron James USA advisers hold individual SEC authorisation, and all are also FCA regulated in the UK. For a US resident, SEC authorisation is the permission that matters; FCA regulation reflects the UK pension expertise behind the advice, and in our experience it also makes UK pension schemes noticeably more comfortable releasing transfers. You can check any adviser’s registration on the SEC’s Investment Adviser Public Disclosure site.
Three Questions to Ask Any Adviser
1. Do you personally hold SEC authorisation, or advise through an SEC-registered firm? Ask for the CRD number and check it on adviserinfo.sec.gov. Make sure it covers the individual advising you, not just a firm name.
2. Are you fee-only? Ask whether any commission, product payment or trail is received on top of your fee.
3. Who handles the US tax side? A good adviser works with a specialist US/UK tax adviser rather than guessing.
Common Mistakes US Residents Make With UK Pensions
1. Taking the 25% lump sum without US tax planning
Many people assume the lump sum is tax free everywhere. In the US it often is not, and taking a large lump sum without planning can produce an unexpected tax bill.
2. Using an adviser without the right US permission
If the person advising you does not hold SEC authorisation, or advise through an SEC-registered firm, they are unlikely to be able to give you compliant advice as a US resident, however long they have worked with UK pensions.
3. Missing US reporting
FBAR, Form 8938 and, for a QROPS, Forms 3520 and 3520-A apply whether or not you draw income. The penalties are material.
4. Planning the pension in isolation
Your UK pension sits alongside Social Security, any 401(k) or IRA, property and your long-term income needs. Optimising it on its own rarely gives the best result.
5. Doing nothing because it feels complicated
An unmanaged UK pension in the wrong structure is not a neutral outcome. It usually means the wrong investments, no drawdown plan, provider restrictions building up and no link to your US retirement planning.
How Cameron James USA Helps US Residents With UK Pensions
Cameron James USA is a specialist cross-border financial planning firm. Our advisers hold individual SEC authorisation and are all FCA regulated in the UK, we are fee-only, and we do not charge initial advice fees on US-connected investments or US pensions.
We work with US residents at every stage: the initial review, the suitability analysis, the transfer itself, and ongoing investment management and drawdown planning. That includes two forward planning meetings a year and cash flow modelling, as set out in our advice process. We work alongside specialist US/UK tax advisers so your pension strategy fits your US tax filing.
Our approach starts with your life (your timeline, income needs, family and other assets) and builds the technical recommendation around it. The pension structure is the vehicle. The destination is a retirement that looks the way you want it to.
Speak to a Cameron James USA Adviser
Your first consultation is free. We will review your UK pensions, explain your options in plain English and tell you honestly whether a transfer makes sense.
Frequently Asked Questions
Can I transfer my UK pension directly to a 401(k) or IRA?
No. UK law only allows transfers to UK registered schemes or to a QROPS, and no US retirement plan is a QROPS. A transfer outside those rules is an unauthorised payment and can trigger UK tax charges of up to 55%.
Can a US resident keep a UK pension?
Yes, and sometimes that is the right decision. There is no requirement to transfer because you have moved to the US. What matters is whether your provider will keep serving you, whether you have flexible drawdown and sensible investments, and whether you can be paid in US dollars without punishing currency costs.
Is the 25% tax-free lump sum tax free in the US?
Not reliably. The general view is that it is taxable in the US, particularly if taken all at once, although there are treaty arguments for taking it gradually, and some states such as California do not follow the federal position. Take advice from a cross-border tax adviser before taking it. Our 25% lump sum guide explains the arguments.
Do PFIC rules apply to my UK pension?
The US-UK treaty is generally understood to remove PFIC tax on funds held inside a UK registered pension such as a SIPP, although some reporting may still apply. Funds held outside a pension, in an ISA or general investment account, are fully exposed to PFIC.
Which International SIPP providers accept US residents?
Only a few, and only through an adviser with US permissions. Morningstar Wealth International and Novia Global are the main integrated options, with iPensions Group and IFGL Pensions as wrapper-only alternatives. For most US residents, Morningstar is our preferred option because it can hold US-domiciled funds and pays interest on cash.
Do I need to file Form 3520 for my International SIPP?
Generally not. A UK SIPP will usually fall within the IRS exemption for tax-favoured foreign retirement trusts in Rev. Proc. 2020-17, even if it is a foreign grantor trust. This is fact-specific, so confirm it with a tax adviser who understands how UK registered pensions interact with the US trust rules.
Do I need to declare my UK pension on US tax forms?
Yes. FBAR is required if your foreign accounts total more than $10k at any point in the year, and Form 8938 above thresholds that depend on filing status. Pension income goes on your Form 1040. These obligations apply even if you are not drawing income.
At what age can I access my UK pension?
From 55 at present, rising to 57 from April 2028 under the Finance Act 2022, though some schemes have a protected pension age. US retirement accounts generally allow penalty-free access from 59 and a half, so the order in which you draw on each is worth planning.
Can I take my whole UK pension as cash?
From a defined contribution pension you generally can, but for most US residents it would be one of the least tax-efficient choices available. Taking everything in one year creates a large income event in the US. Model it with a cross-border tax adviser before signing anything.
Can I still contribute to my UK pension as a US resident?
UK tax relief on contributions is limited to UK residents, with a narrow exception for up to five tax years after leaving. For most US residents, new retirement savings are better directed to a 401(k), a Traditional or Roth IRA or, for the self-employed, a SEP IRA.
What happens to my UK pension when I die?
Undrawn funds in an International SIPP can pass to the beneficiaries you nominate. Before 75 they are generally free of UK income tax for the recipient; after 75 they are taxed at the beneficiary’s rate. From April 2027, unused pension funds also fall within UK Inheritance Tax. The US treatment of inherited UK pensions needs separate advice.
My UK provider says it can no longer serve me. What do I do?
This is increasingly common. Treat it as a chance to consolidate your UK pensions into a properly structured International SIPP, and do not move hastily to whichever provider will take you just to meet the deadline.
How long does a UK pension transfer take?
DC pensions on modern platforms typically transfer in four to eight weeks. Older workplace schemes, DB pensions and slower providers can take two to six months. In our experience, transfers are often much quicker when the adviser is on the FCA register, because UK schemes are more comfortable dealing with an FCA-regulated adviser, even though it is not technically the relevant permission for a US resident.
How much does a transfer cost with Cameron James USA?
Our initial fee is a fixed £2.5k for DC (£4.5k for DB) plus 0.5% of the transfer value, with £1k added for more than one pension, capped at £12k for DC and £15k for DB. We are fee-only, and we do not charge initial advice fees on US-connected investments or US pensions.
Related Articles
- International SIPP for US residents
- QROPS transfers for US residents
- Final salary (DB) pension transfer for US residents
- Malta QROPS: Form 3520 and IRS treatment
- Is the UK 25% lump sum tax free in the US?
- UK pension transfer fees for US residents
- Novia Global vs Morningstar International SIPP
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.
