Your Complete Guide — FCA and SEC Authorised Advisers for UK Pension Advice

If you hold a UK pension and are now living in the United States, you are navigating one of the most technically demanding areas of cross-border financial planning. You face two tax systems, two regulators, a bilateral tax treaty that pre-dates pension freedoms, and a marketplace full of advisers who understand one side of the equation, but rarely both.

This guide covers everything you need to know: your options, potential tax implications, the regulatory framework, what a well-run transfer process looks like, and, critically, the lifestyle questions that should drive every decision you make. Because the goal is not just an optimised pension structure. The goal is a retirement that looks and feels exactly the way you want it to.

All advisers operating under Cameron James USA are authorised by the Financial Conduct Authority (FCA) in the UK and registered with the Securities and Exchange Commission (SEC) through Beacon Global Advisor Network, LLC. Whilst all US advice must be given under an SEC licence, having an FCA-regulated adviser provides a significant additional layer of comfort and professional accountability.

55% UK tax charge on unauthorised transfers

35% Max IRS penalty QROPS non-compliance

£268k Lump Sum Allowance 2025/26

Age 57 Min. UK pension access from April 2028

1. Can You Transfer a UK Pension to the US?

The short answer is no. You cannot transfer a UK pension directly into a US retirement account such as a 401(k) or an IRA. HMRC does not recognise US retirement plans as approved receiving vehicles for UK pension transfers, and the two systems have no structural compatibility.

What you can do is transfer your UK pension into a structure specifically designed for non-UK residents, including US residents. The two relevant vehicles are an International SIPP and a QROPS. For the overwhelming majority of US residents, only one of those is appropriate, and this guide explains why in detail.

Before addressing those options, it is worth asking a prior question: Should you transfer at all? A transfer is not automatically the right answer. The starting point for any properly conducted review is an honest assessment of what you actually need your pension to do, and whether it can already do that where it currently sits. If you have a Defined Benefit pension, this question is even more important, and only an FCA-regulated pension transfer specialist can help you answer it properly.

2. Start With Lifestyle, Not Structures

The technical options available to you, International SIPP, QROPS, leaving things where they are — are all means to an end. That end is your retirement. Before discussing products, a good adviser should be asking you an entirely different set of questions:

Questions that should shape every pension decision

• When do you want to stop working, and what does that transition look like?
• Where will you be living in retirement, e.g. permanently in the US, or splitting your time?
• What income will you need in Year 1 of retirement, and how might that change over 10-20 years?
• Do you have a spouse or partner whose retirement plans are intertwined with yours?
• What other retirement assets do you have? 401(k), IRA, Social Security entitlement, property?
• How do you feel about investment risk, and how would a 20% fall in your portfolio affect your plans?
• Do you want to pass assets to the next generation, or is your goal to spend the money yourself?
• Is there any realistic chance you return to the UK, or is that chapter firmly closed?

These questions are not a preamble before the real advice begins. They are the real advice. The pension structure that serves a 52-year-old in Texas planning to retire at 60, split their time between the US and Europe, and leave a meaningful inheritance to two adult children is very different from the structure that serves a 64-year-old in New York who wants maximum income now and has no dependants.

Lifestyle financial planning means building the technical recommendation around your life, not the other way around.

3. Your Options as a US Resident

With lifestyle context established, there are broadly three paths available for managing a UK pension from the United States:

Option	Summary
Leave it where it is	Pension remains with the existing UK provider. Income is drawn at retirement. Suitable only if the provider offers international payment capabilities and appropriate investment flexibility. More common where the pension is still within an employer-based scheme.
Transfer to an International SIPP	Pension moves to a UK-based, FCA-regulated, HMRC-approved scheme built for non-UK residents. Most commonly appropriate for US residents with defined contribution pensions.
Transfer to a QROPS	Pension leaves the UK system entirely and moves to an overseas scheme recognised by HMRC. Rarely appropriate for US residents due to adverse IRS treatment. See Section 5.

4. What Is an International SIPP?

An International SIPP (Self-Invested Personal Pension) is a UK-registered, HMRC-approved pension scheme built specifically for individuals who have accumulated UK pension assets but are now resident overseas.

It remains within the UK pension regulatory framework, regulated by the FCA, covered by the Financial Services Compensation Scheme (FSCS), and treated as a pension by HMRC. That matters because it means your funds continue to benefit from UK pension protections, including favourable UK inheritance rules and treaty-protected status for US tax purposes.

What an International SIPP can provide that a legacy UK pension typically cannot:

• Flexible drawdown: take income in amounts and at times that match your lifestyle needs, rather than being locked into an annuity or a rigid schedule.
• Investment choice: access to globally diversified, low-cost index funds and ETFs, rather than the limited and often expensive default funds inside old employer pensions.
• Currency flexibility: hold the pension in US dollars and receive income paid directly to a US bank account, removing ongoing currency conversion friction.
• Consolidation: multiple UK pension pots from different employers can be brought together into a single, managed account.
• Regulated advice: managed by an adviser regulated in the US, giving you coordinated, compliant guidance across both systems.

From a lifestyle planning perspective, the income flexibility is particularly significant. The ability to draw more in years when you have higher expenditure, e.g. a home renovation, a significant trip, a large gift to children, and less in quieter years gives you meaningful control over both your lifestyle and your annual tax position.

Who does an International SIPP suit?

Broadly, any US resident with defined contribution UK pension assets, meaning a pension where you have a pot of money rather than a guaranteed income from a final salary scheme. It is especially valuable for those with multiple pensions, those whose existing providers are restricting service to non-UK residents, and those who have no active advice or management on their pension and want to change that. It may also suit someone with a Defined Benefit pension, but only in specific circumstances.

5. What About QROPS? A Warning for US Residents

A QROPS (Qualifying Recognised Overseas Pension Scheme) is an overseas pension scheme that HMRC has approved to receive UK pension transfers. When you transfer to a QROPS, your pension leaves the UK tax and regulatory framework and moves to the jurisdiction of the QROPS provider, commonly Malta, Gibraltar, or Guernsey.

QROPS were designed primarily for individuals permanently emigrating to a country where a local QROPS provides specific structural or tax advantages. For US residents, they are seldom appropriate, and the reason is a serious one.

IRS Risk The United States does not recognise QROPS as pension vehicles for US tax purposes. A QROPS held by a US person is typically treated by the IRS as a foreign grantor trust, triggering mandatory annual filing of Forms 3520 and 3520-A. These are complex, specialist filings. Non-compliance carries penalties of up to 35% of the trust’s value in a single year.

In addition, once your pension has left the UK system via a QROPS, it no longer sits within the framework of the US-UK Double Taxation Agreement (DTA) in the same way as a UK-registered scheme. The treaty protections that reduce your US tax exposure on pension income are less clearly available to a QROPS than to an International SIPP.

There are narrow circumstances where a QROPS might be considered for a US-connected individual, typically involving dual nationality, specific domicile positions, or very large pension pots with complex cross-border estate planning requirements. These cases exist and require specialist legal and tax input. But they are the exception.

Red Flag Warning If an adviser is recommending a QROPS for you as a US resident without a detailed, written explanation of your specific IRS filing position and the foreign grantor trust implications, treat that as a serious red flag.

6. What If You Leave the Pension Where It Is?

This is a completely legitimate option and one worth considering honestly. If your existing UK pension provider offers flexible drawdown, a broad investment menu, and the ability to pay income directly to a US bank account, you may not need to transfer at all. A good adviser’s first question should always be whether a transfer actually adds value in your specific circumstances.

Scenarios where leaving things alone makes sense:

• Your existing provider offers full international service for non-UK residents.
• Your pension is small enough that the cost of transferring outweighs the benefit.
• You are within two to three years of your target retirement date, and consolidation would be disruptive without a sufficient payback period.
• You are considering returning to the UK in the medium term.
• The scheme has full flexible access and remains inside an employer pension scheme.

Scenarios where inaction becomes a problem:

• Your provider has written to you requiring a transfer out, several major UK platforms, including Standard Life and Interactive Investor, have issued notices to US-resident clients with deadlines in 2025 and 2026.
• Your pension is sitting in an unsuitable default fund with no active management, gradually drifting away from an appropriate risk position.
• You cannot receive income payments to a US bank account and/or face punitive conversion charges.
• You have three, four, or five separate pension pots with different providers and no consolidated view of your retirement position.
• You are receiving no advice at all, which means nobody is monitoring whether your pension strategy remains aligned with your evolving life plans.

7. How Is Your UK Pension Taxed in the United States?

This is the area that causes the most confusion, and the most expensive mistakes. As a US person (whether a citizen, green card holder, or tax resident), you are subject to US federal tax on your worldwide income. UK pension income sits within that scope.

The Tax-Free Lump Sum (Pension Commencement Lump Sum — PCLS)

In the UK, you are generally entitled to take up to 25% of your pension pot as a tax-free lump sum at retirement. Following the abolition of the Lifetime Allowance charge in April 2023, the maximum PCLS is now capped at the Lump Sum Allowance of £268,275 (for the 2025/26 tax year), unless you hold a valid form of protection that preserves a higher entitlement.

In the United States, the position is more complex. The US-UK Double Taxation Agreement (DTA) does not provide a straightforward exemption for the lump sum in the way UK legislation does. The IRS has historically taken the position that the PCLS is taxable as income in the US, though arguments to the contrary have been made by practitioners based on Article 17 of the DTA. This also varies state by state, making it a genuinely contested area. Any specific advice on lump sum treatment should come from a qualified cross-border tax adviser reviewing your individual circumstances.

Planning PointIf you are contemplating taking your PCLS, this decision should never be made in isolation. The US tax treatment, the interaction with Social Security timing, your other income sources in that tax year, and the marginal federal and state tax bracket implications all need to be modelled before you act.

The Income Element

Pension income drawn in excess of any PCLS, whether via drawdown or annuity, is taxable in the US at your marginal federal income tax rate. State tax may also apply, depending on your state of residence. Some states, notably Florida, Texas, and Nevada, have no state income tax. Others treat retirement income less favourably.

The key planning discipline is managing how much you draw in any given year. Thoughtless drawdown can push income into a higher federal bracket unnecessarily, trigger IRMAA surcharges on Medicare premiums, or reduce the efficiency of Social Security planning. Annual coordination between your UK pension drawdown strategy and your overall US tax position is not a luxury, it is standard practice in well-run cross-border financial planning.

8. The US-UK Double Taxation Agreement

The US-UK Double Taxation Agreement (DTA), in force since 2003, governs the allocation of taxing rights between the two countries when you have connections to both.

The core principle under Article 17 of the DTA is that pension income paid to a US resident from a UK pension scheme is generally taxable only in the United States. This prevents double taxation, you should not be paying UK income tax on your pension income if you are US-resident and correctly claiming treaty relief.

In practical terms, this means:

• UK income tax should not be withheld at source on your UK pension if you have correctly completed HMRC Form DT-Individual to claim treaty relief and have the scheme apply NT (Nil Tax) coding.
• The income is reported and taxed on your US federal return (Form 1040).
• The UK retains limited taxing rights in specific circumstances — for example, in relation to government service pensions, where Article 18 of the DTA may apply.

The DTA was drafted before the pension freedoms legislation of 2015, and several areas, particularly the treatment of flexible drawdown, the PCLS, and death benefits, are not explicitly addressed by the treaty text. This creates genuine areas of ambiguity that require careful, qualified advice. Do not rely on general summaries of the DTA for your specific position.

Additionally, HMRC may still apply emergency tax or incorrect coding to pension payments even where treaty relief has been claimed. Monitoring this and reclaiming any overpaid tax is an ongoing administrative responsibility that your adviser should be supporting you with.

9. Defined Benefit (Final Salary) Pension Transfers

If your UK pension is a defined benefit (DB) scheme, commonly called a final salary pension, the analysis is more complex and the stakes considerably higher.

A DB pension provides a guaranteed income in retirement, typically calculated as a fraction of your final or career-average salary multiplied by your years of service. It usually includes inflation-linked increases, a spouse’s pension on death, and in many cases a fixed normal retirement date. These are genuinely valuable features that cannot be replicated cheaply through investment.

When you transfer a DB pension, you exchange that guaranteed income for a Cash Equivalent Transfer Value (CETV), a lump sum calculated by the scheme actuary, which is then invested in a SIPP or other pension structure. The guarantee disappears. From that point, your retirement income depends entirely on investment performance and the size of your pot.

Legal Requirement Under FCA rules, if your DB pension (or any other pension with safeguarded benefits) has a transfer value of £30,000 or more, you are legally required to take regulated advice from a pension transfer specialist before any transfer can proceed. This is not optional. As a US resident, you will also need SEC-authorised advice on any potential new pension scheme and investments.

When might a DB transfer make sense for a US resident?

• You have ill health, and a materially lower life expectancy means the chances of obtaining benefits equal to the value of the CETV are reduced.
• The scheme’s funding position is weak, and you have concerns about the employer’s long-term solvency (though the Pension Protection Fund provides a safety net).
• The CETV is high relative to the projected income, transfer values in excess of 25-30 times annual income were common prior to 2022, but have fallen considerably from peak levels.
• Flexibility is important, you want to draw a variable income rather than a fixed monthly amount.
• Death benefits are a priority, a SIPP allows pension assets to be inherited in full and passed down the generations more efficiently than a typical DB spouse’s pension.
• You have ample other guaranteed or secure income (Social Security, UK State Pension, other DB pensions, rental income) meaning you do not rely on this pension for basic living expenses.

When does a DB transfer usually not make sense?

• The guaranteed income would be very expensive to replicate through investment at current yields.
• You are several years away from the scheme’s normal retirement date.
• You value certainty of income over flexibility, particularly important if your expenditure is relatively fixed and predictable.
• The scheme is well-funded and the employer is financially sound.
• You are in good health.
• The CETV offered is poor value relative to the income that would be given up.

Every DB pension and every individual situation is different. Any adviser who gives you a categorical answer, whether to transfer or not to transfer, without completing a detailed, documented suitability analysis is not meeting the regulatory standard required.

10. US Reporting Obligations You Cannot Ignore

As a US person with a UK pension, you have annual reporting obligations to both the IRS and FinCEN (the Financial Crimes Enforcement Network). Failure to meet them can result in significant civil penalties, and in some circumstances, criminal liability.

FBAR — FinCEN Form 114

If the aggregate value of your foreign financial accounts exceeds $10,000 at any point during the calendar year, you are required to file an FBAR. UK pensions are financial accounts for FBAR purposes. The FBAR is filed electronically with FinCEN and is separate from your tax return. The deadline is April 15, with an automatic extension to October 15.

Form 8938 — FATCA

Under FATCA, you must report specified foreign financial assets on Form 8938 if they exceed certain thresholds ($50,000 for single filers, $100,000 for joint filers, with higher thresholds for those living outside the US). UK pensions are reportable assets. Form 8938 is attached to your Form 1040.

Form 3520 / 3520-A

This is the form set that catches many QROPS holders by surprise. If your pension structure is characterised as a foreign grantor trust by the IRS, the default position for most QROPS arrangements, annual filing of Forms 3520 and 3520-A is required. An International SIPP, by contrast, remains within the UK pension framework and is treated as a pension for US purposes under the DTA. The difference in reporting burden between an International SIPP and a QROPS is substantial.

Cross-border US-UK tax filing is a specialist discipline. Cameron James works alongside qualified US tax professionals who understand the pension treaty provisions and can ensure your annual compliance is handled correctly.

11. What Does a UK Pension Transfer Cost?

Fees in the cross-border pension advisory market vary widely, and the industry has historically lacked transparency. It is worth being direct about how this works.

The Industry Standard

Most expat-focused financial advisers charge a percentage of the pension value for the initial transfer — typically between 1% and 3%, occasionally higher. On a £300,000 pension, a 2% fee is £6,000. On a £600,000 pension at the same rate, it is £12,000. Ongoing annual management fees typically sit between 0.75% and 1.5% of the portfolio value.

What Cameron James Charges

Cameron James charges a hybrid fee structure. For DC pensions, the fee is £3,000 + 0.5% above £100k. For example, an £800k transfer would cost £6,500, regardless of how many schemes are involved. For DB pensions, the fixed fee element is £5,000, and the FCA-regulated pension transfer specialist will also charge a report fee of at least £3,000. Our ongoing advice fee is tiered and disclosed on our website. We do not charge initial fees for non-UK pension advice.

Total Cost of Ownership

When comparing advisers, always ask for the total annual cost expressed as a percentage of your pension value — covering adviser fee, SIPP fee, platform fee, and average underlying fund charges. With a well-constructed International SIPP using low-cost index funds, total costs typically sit between 1% and 1.50% per annum. A reputable adviser will model these costs clearly and help you understand the long-term compound effect of different cost levels on your retirement income.

12. The Transfer Process — Step by Step

For a defined contribution pension transferring to an International SIPP, the process follows a broadly consistent sequence:

Stage	What happens
1. Discovery & Assessment	Full review of your existing pensions — type, value, provider, features, and any guarantees. Establishes your wider financial picture: other assets, income needs, tax position, and lifestyle objectives.
2. Suitability Analysis	Your adviser produces a detailed suitability report covering whether a transfer is in your best interests, which structure is most appropriate, and the recommended investment strategy. For DB pensions, this stage is more extensive and must be completed by an FCA-regulated pension transfer specialist.
3. Platform Selection	Recommendation of a specific International SIPP provider, if a transfer is suitable. The right choice depends on your pension size, currency requirements, investment preferences, and costs.
4. Account Opening	The International SIPP account is opened, including standard AML and KYC documentation — proof of identity, address, and source of funds.
5. Transfer Initiation	Formal transfer request submitted to your existing UK provider(s). DC transfers can complete in 4-12 weeks; DB transfers may take 3-6 months.
6. Investment	Funds are invested in accordance with the agreed strategy. If the suitability analysis was thorough, the portfolio will have been agreed in advance, and implementation follows immediately.
7. Ongoing Management	Annual reviews, goals-based financial planning, portfolio rebalancing, drawdown planning, and coordination with your US tax filing. The relationship does not end at transfer completion.

13. The Adviser Regulatory Question — Why It Matters

To give regulated financial advice to a US resident, including advice on investments, pension strategy, and drawdown planning, an adviser must be registered with the SEC (or FINRA, depending on the nature of the advice). FCA authorisation alone is not sufficient. An FCA-authorised firm advising US residents on investment matters without SEC registration is acting unlawfully under the US Investment Advisers Act 1940. There are narrow exemptions, but these are available only for incidental contact and are not an option for specialist advisers.

This is not a technicality. An unregistered adviser cannot legally advise a US resident, and you may have no regulatory recourse if something goes wrong. The FCA has no jurisdiction over US advice, and the SEC has no record of an unregistered adviser.

Cameron James USA advisers are registered with the SEC through Beacon Global Advisor Network, LLC (CRD number available on request via the SEC’s IAPD database). All advisers under Cameron James are also FCA-regulated.

Two Questions to Ask Any Adviser 1. Are you SEC-registered or acting through an SEC-registered entity? 2. Are you also FCA authorised? The FCA authorisation is technically only relevant for UK residents, but it provides a significant boost to confidence — FCA standards are widely regarded as the gold standard in financial advice regulation. Critically, ensure the specific adviser is regulated, not just the firm they work for.

14. Common Mistakes US Residents Make with UK Pensions

Mistake 1: Taking the PCLS Without US Tax Planning

Many people take their 25% lump sum assuming it is tax-free globally. The US tax position is more nuanced, and taking a large lump sum without understanding the federal income tax exposure can produce an unexpectedly large tax bill.

Mistake 2: Receiving Advice from an Unregistered Adviser

A firm that is not SEC-registered cannot legally advise US residents on investment matters, except under very narrow exemptions. If your adviser does not hold SEC authorisation, they likely cannot give you regulated, compliant advice.

Mistake 3: Not Meeting US Reporting Obligations

FBAR, Form 8938, and in some cases Forms 3520/3520-A are mandatory for US persons with UK pensions. The penalties for non-compliance are potentially severe. Ensure your tax adviser has specific cross-border experience.

Mistake 4: Optimising the Pension Without Reference to the Bigger Picture

Your UK pension does not exist in isolation. It sits alongside Social Security, possibly a 401(k) or IRA, potential property assets, and your long-term income needs. Optimising the pension without reference to the whole picture is unlikely to produce the best outcome.

15. Frequently Asked Questions

Can a US resident keep their UK pension?

Yes — and in many cases that is exactly the right decision. There is no legal requirement to transfer your UK pension simply because you have moved to the United States. The more important questions are whether your current provider can serve you as a non-UK resident, whether you have genuine investment flexibility and access to drawdown options, and whether you can receive payments in US dollars without punishing currency conversion costs.

What needs to change is the quality of advice sitting around that pension. A UK pension held by a US resident sits at the intersection of two regulatory systems, two tax codes, and a bilateral tax treaty. Without joined-up guidance from an adviser regulated in both jurisdictions, the pension can become a compliance liability rather than a retirement asset.

At what age can I access my UK pension?

UK pensions can currently be accessed from age 55. Under the Finance Act 2022, this minimum access age is legislated to rise to 57 in April 2028, though a small number of schemes with a protected pension age may retain access from 55.

It is worth noting the contrast with US retirement accounts: a 401(k) or Traditional IRA can generally be accessed from age 59½ without the 10% early withdrawal penalty. If you are drawing on both, sequencing withdrawals across both systems, to manage your US marginal tax brackets year by year, is one of the most valuable things a cross-border financial plan can do.

Can I take my entire UK pension as a cash lump sum?

Under the pension freedoms introduced in April 2015, you generally can if it is a defined contribution scheme. For most US residents, however, this would be among the least tax-efficient decisions available. Taking your full pension value in a single tax year creates a single large ordinary income event in the US. Depending on the size of your pension, this could push you into the 37% federal bracket, and potentially trigger state income taxes on top. Any whole-fund withdrawal strategy should be modelled comprehensively, with a US-qualified cross-border tax adviser involved, before a single form is signed.

Can I still contribute to my UK pension as a US resident?

UK tax relief on pension contributions is available only to UK residents, with limited exceptions for those who have been non-resident for fewer than five consecutive tax years. Once settled in the US beyond that window, the primary economic incentive for further UK pension contributions no longer applies.

For most US residents, new retirement savings are better directed towards US-based vehicles: a 401(k) through your employer, a Traditional or Roth IRA depending on your income and tax position, or, for the self-employed, a SEP-IRA. Your existing UK pension continues to grow and can be drawn down in retirement; the focus simply shifts to building the US side of the picture.

What happens to my UK pension if I die as a US resident?

Death benefits under UK pensions depend on the type of scheme and, critically, your age at death. For an International SIPP, undrawn funds can be nominated to beneficiaries of your choice. If death occurs before age 75, those funds are generally free of UK income tax for the recipient. If after age 75, they are paid subject to income tax at the beneficiary’s marginal rate.

Two developments make this area particularly important to plan around at present: From April 2027, unspent UK pension funds will for the first time fall within the scope of UK Inheritance Tax, a significant change for anyone with a substantial pension and UK-connected estate planning. The US tax treatment of inherited UK pension assets is a separate question that sits outside the UK rules entirely and requires specific cross-border advice. If you hold a UK pension and have a US-based family, estate planning across both jurisdictions should be reviewed before April 2027.

Do I need to declare my UK pension on US tax forms?

Yes. US residents with foreign financial assets have mandatory reporting obligations, and a UK pension falls within scope:

• FBAR (FinCEN Form 114): required if the combined value of your foreign accounts exceeds $10,000 at any point in the year.
• FATCA (Form 8938): required above thresholds that vary depending on your filing status and whether you are resident in the US ($50,000 for single filers at year-end).
• Form 1040: pension income is declared as ordinary income. Withholding treatment and treaty exemptions may apply depending on your circumstances.
• Additional forms may be required depending on your specific pension structure and any trust elements involved.

The penalties for non-compliance are material. FBAR violations can result in penalties of up to $10,000 per year for non-wilful violations, significantly more if wilful. Qualified cross-border tax advice is not optional in this area.

How long does a UK pension transfer take?

It depends on your current scheme. Defined contribution pensions on modern platforms can typically transfer in four to eight weeks. Transfers from older workplace schemes, deferred defined benefit arrangements, or providers with slower administration processes can take two to six months, and occasionally longer. Your adviser should give you a realistic timeline estimate for your specific providers before you begin.

Can I transfer my UK pension directly to a 401(k) or IRA?

No. There is no compliant mechanism to transfer a UK-registered pension scheme directly into a US retirement vehicle such as a 401(k), Traditional IRA, or Roth IRA. UK legislation only permits overseas transfers to Qualifying Recognised Overseas Pension Schemes (QROPS), a specific category of overseas scheme approved by HMRC. No mainstream US retirement plan currently holds QROPS status. Attempting to transfer to a non-qualifying scheme would be treated by HMRC as an unauthorised payment, triggering a UK tax charge of up to 55% of the transfer value.

The 55% unauthorised payment charge is not a theoretical risk. Poorly advised transfers have cost clients hundreds of thousands of pounds. If you have been told you can roll your UK pension into a US IRA, seek a second opinion from a dual-regulated adviser before taking any action.

My UK pension provider says they can no longer serve me as a US resident. What do I do?

This is increasingly common. Many mainstream UK pension providers, including some of the largest platform operators, have reviewed their obligations under US law and concluded that continuing to service US residents creates regulatory exposure they are unwilling to accept. The result is that US-resident clients receive notices requiring them to transfer out, often within a fixed deadline.

This is not a crisis, but it does require prompt and careful action. The key is to transfer to a platform genuinely equipped to serve US residents: one whose provider has the compliance infrastructure to accept FATCA-regulated clients and whose investment options are structured to avoid creating additional US reporting problems.

The wrong response is to transfer hastily to any available provider simply to meet a deadline. The right response is to use the forced transfer as an opportunity to consolidate any other UK pensions you hold and establish a structure, typically an International SIPP, built for your cross-border situation from the outset.

What is an International SIPP, and how is it different from a standard SIPP?

A Self-Invested Personal Pension (SIPP) is a UK-registered pension that gives the holder control over how their pension assets are invested. A standard SIPP is designed for UK residents and offered by most large UK platforms. An International SIPP is a SIPP specifically structured for people resident outside the UK.

The practical differences for US residents are considerable. Standard SIPPs are typically closed to US-resident clients due to SEC compliance concerns. International SIPP providers have built a compliance framework to accept and serve non-UK residents. They typically allow you to hold assets and receive drawdown payments in US dollars, removing ongoing currency conversion costs. The International SIPP also remains a UK-registered pension — retaining FSCS protection and staying within the UK regulatory framework, meaning it is not treated as an offshore or foreign trust structure by HMRC.

What does the US-UK Double Taxation Agreement mean for my pension income?

The US-UK Double Taxation Agreement is the legal framework determining which country has the primary right to tax your pension income. For private and workplace pensions, Article 17 of the DTA is the operative provision. The general rule under Article 17(1) is that pension income is taxable only in the country of residence — so for a US resident receiving income from a UK SIPP or defined benefit scheme, the income is taxable in the US and, in principle, not subject to UK income tax.

Important nuances include: the IRS may treat the 25% lump sum as taxable ordinary income; US residents typically need to apply to HMRC for an NT (No Tax) code to avoid UK PAYE being withheld at source; and US citizens are subject to the US savings clause, which means the US retains the right to tax its citizens as if the treaty did not exist, adding complexity for US citizens living abroad.

Do I need to file IRS Form 3520 for my UK pension?

The general position is that employer-sponsored foreign pension plans (including UK workplace pensions) can qualify for an exception from Form 3520 reporting under IRS Notice 97-34, provided there were no contributions or distributions during the tax year. An International SIPP that is structured and operated in a compliant manner is generally not treated as a foreign grantor trust requiring Form 3520 filing. However, this analysis is fact-specific and depends on the exact structure of your pension, it should be confirmed by a qualified cross-border tax adviser familiar with how HMRC-registered pension schemes interact with IRS trust rules.

Cameron James does not provide tax advice. We work alongside qualified US-side CPAs and cross-border tax specialists and can refer clients to advisers with specific experience in this area where needed.

How Cameron James Can Help

Cameron James is a specialist cross-border financial planning firm. Our advisers are all authorised by the FCA in the UK, and all of our US client advisers are also registered with the SEC through Beacon Global Advisor Network, LLC. That combination is rare, and it is the minimum regulatory standard for giving you advice that is properly compliant on both sides of the Atlantic.

We work with US residents at every stage of the pension journey: from initial assessment and suitability analysis, through the transfer process, to ongoing drawdown planning, investment management, and annual reviews. We work alongside specialist cross-border tax professionals to ensure your pension strategy integrates correctly with your US tax filing.

Our approach starts with your life, your retirement timeline, your income needs, your family circumstances, your other assets, and builds the technical recommendation from there. The pension structure is the vehicle. The destination is a retirement that looks the way you want it to.

Get Started — No ObligationIf you have a UK pension and are living in the United States, we are happy to provide an initial assessment of your position with no obligation and no upfront cost. You will come away with a clear picture of your options, the regulatory requirements that apply to your situation, and an honest view of whether a transfer adds value for you specifically.Visit cameronjames.com to arrange your complimentary review.

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