US Resident SIPP: Your Complete Guide to SIPP Transfers and Consolidation for US Residents

Introduction

If you’re a UK national now living in the United States, or a US resident with accumulated UK pensions, you may be asking: “What do I do with my UK pension pots now I’m in the US?” 

You’re not alone. Many cross-border clients worry about how to maintain flexibility, remain tax-compliant and avoid pitfalls when dealing with UK pensions while resident in the US.At Cameron James USA, we specialise in helping US-resident clients with UK pensions navigate the complex junction of UK pension law, US tax and reporting, and finding the right SIPP (Self-Invested Personal Pension) structure that works for your unique situation.
We’ll walk you through what you can and can’t do, what options you have, and how our process delivers clarity, compliance, and control.

Can you transfer a UK pension directly into a US retirement account?

A commonly held misunderstanding is that you can move a UK pension directly into a US retirement vehicle, such as a 401(k), traditional IRA or Roth IRA. 

Unfortunately: no, you cannot.

Here’s why:

• UK pension legislation only allows transfers to overseas pensions which are recognised by HMRC as a Qualifying Recognised Overseas Pension Scheme (QROPS).
  
• The United States currently has no retirement plans that are QROPS.
  
• Attempting an unauthorised transfer could trigger a UK unauthorised payment tax (up to 55%) and create US tax/reporting complications
  

Thus, the direct rollover to a US-based plan is off the table, and attempting this is a high-risk strategy with little or no reward.

What are your practical alternatives?

As a US resident holding UK pensions, you essentially have two main routes:

Option A: Leave the UK pension where it is

Pros:

• You retain the existing UK scheme and regulatory protection under the UK system, such as the Financial Conduct Authority (FCA) oversight or UK provider protections.
• No immediate transfer costs.
• It may be a scheme that does not limit non-UK Resident options, even death benefits
  

Cons:

• Some UK pension providers may refuse service to US residents or restrict investment or withdrawal flexibility.
• You may have limited access to flexible drawdown, limited investment options, or multi-currency choices.
• Death benefits for your loved ones may be limited, resulting in undesirable inflexibility and tax consequences
  
• Administration and reporting may become more complex (e.g., US tax disclosure, currency risk, estate/inheritance implications).
  

In short, leaving the pension where it is can work, but only if your UK provider supports non-UK residents, and you’re comfortable with the likely limitations.

Option B: Transfer into a UK-based International SIPP designed for US residents

In most cases, our view is that this is the preferred route for US-resident clients with UK pension pots. At Cameron James USA we talk about an “International SIPP”, a UK-regulated SIPP structured for non-UK residents, rather than dozens of offshore or exotic alternatives.

Key advantages include:

• UK regulatory protection: the SIPP remains under UK rules (FCA regulation, UK trustee oversight) so you retain the comfort of UK standards. 
• Consolidation: You can bring multiple UK pensions (defined contribution, old personal pensions) into one plan, simplifying management.
  
• Investment flexibility: Access to global ETFs, low-cost funds, ability to hold USD/GBP, and withdraw to your US bank account
  
• Currency control: If you hold USD or arrange USD-denominated investments, you may mitigate GBP-USD currency risk.
  
• Estate/inheritance planning benefits: A SIPP may offer efficient succession planning, especially if you die before age 75 (UK IHT rules may be favourable).
  

Important caution: This is still a UK pension vehicle. UK “tax-free” lump sums, US tax treatment, reporting (FBAR/FATCA), and investment structuring need thorough planning. At Cameron James USA, we always work alongside a US CPA or tax advisor.

Tax & Regulatory Landscape: What US residents with UK pensions must know

UK–US Double Taxation Treaty

As a US tax resident with UK pensions, you’re subject to the US tax on worldwide income. The good news: the UK–US Double Taxation Agreement means generally your UK pension income is taxed only in the US, not also in the UK.

How the IRS views UK pensions

• The IRS treats your UK pension similar to a defined-contribution plan, like a 401k or Traditional IRA: growth is tax-deferred until withdrawal
  
• Withdrawals from the pension will typically be taxed as ordinary income in the US, subject to Federal and State taxes, where applicable
  
• The UK “25% tax-free lump sum” is not guaranteed tax-free in the US. It may be treated as taxable income, and our general view is that it is taxable, but that is for you to decide, in co-ordination with your accountant/tax adviser.

Reporting obligations

If you maintain non-US financial assets (including UK pensions), you may trigger FBAR or FATCA obligations. A poorly structured pension or unreported transfers can lead to penalties. 

This is one reason why US-resident clients often need an adviser who understands both sides of the cross-border picture.

Regulatory/regime risks

• Some offshore pension schemes or QROPS are poorly served for US residents; the IRS may treat them as foreign trusts, increasing complexity and risk.
  
• Transfers into non-recognised schemes (by HMRC) can trigger UK tax charges; US regulators expect proper reporting and compliance by US-resident advisers.

Why choose Cameron James USA to help you

At Cameron James USA, we bring together cross-border expertise you can trust—connecting UK pension law, US tax/regulation and globally mobile retirement planning. Here are the key differentiators:

• We have advisers with UK (FCA) and US (SEC) regulatory awareness.  While FCA-licensing doesn’t apply to US residents, it signals high-quality UK pension advice standards.
  
• We are fee-based and transparent: no hidden commissions, with clear fee breakdowns.
  
• End-to-end service for US-resident UK pension holders: from discovery call → pension/fund review → formal advice → implementation → ongoing planning. 
• We coordinate with UK trustees, pension providers, US tax advisors and SIPP trustees. 

• We also advise on US-based assets, providing seamless, coordinated cross border financial planning, covering your assets on both sides of the pond, if not further afield.
  
• We support global investment access (ETFs, low-cost funds) tailored for US tax-reporting, currency management (USD/GBP) and flexible drawdown strategy
  
• We help you avoid regulatory and compliance pitfalls, especially those unique to US-resident UK pension holders (e.g., unauthorised payments, QROPS complications, US tax traps).
  

If you’re seeking a trusted partner for UK pensions in a US-resident context, Cameron James USA offers both strategic clarity and technical depth.

Ideal candidate: Is this you?

You may benefit from our UK-pension/SIPP service if:

• You are a UK national (or have UK pensions) now resident in the US.
  
• You hold multiple UK pension pots (defined contribution or earlier personal pensions) and would like consolidation and simpler reporting.
  
• You want investment flexibility (e.g., global ETFs), currency control (USD/GBP) and withdrawals aligned with US residence.
  
• You expect to spend your retirement in the US (or move countries again) and need portability, transparency and cross-border compliance.
• Your loved ones also live outside the UK, and you want to ensure your pension can be passed to them according to your wishes
• You are concerned about UK providers refusing US-resident business, or you’re already experiencing account restrictions, higher costs or inferior investment options.

Frequently Asked Questions (FAQ)

Q1. Can I consolidate several UK pensions while living in the US?
Yes, you can transfer multiple defined contribution UK schemes into a single International SIPP aimed at US residents.

Q2. How long does a UK-to-SIPP transfer take?
It depends on how quickly your UK providers release paperwork and funds. Many transfers take 4-12 weeks, depending on complexity and trustees.

Q3. If I die, how are UK pensions in a SIPP treated for inheritance?
With a UK SIPP, if you die before age 75 then the pension fund may pass to beneficiaries free of UK Inheritance Tax. But you must still consider US estate tax and beneficiary US tax treatment.

Q4. What happens to the 25% UK tax-free lump sum once I become a US resident?
Often, the IRS treats that lump sum as taxable income in the US. You should consult your US tax advisor. Cameron James USA supports coordinating planning for this.

Q5. What if I later move back to the UK or another country?
An International SIPP remains UK-regulated, so it works if you repatriate or move abroad again. Flexibility is one of the design points.

Steps for moving forward with Cameron James USA

1. Discovery Call:  We review your residency status, current UK pension schemes, your US tax position and goals.
   
2. Financial Review:  We evaluate your pension options, trustee/provider restrictions, costs, FX exposure, investment compatibility, tax impact. We will also review your wider financial planning needs.
   
3. Formal Advice:  You’ll receive a written Suitability Report including our recommended solution, cost breakdown and rationale.
   
4. Implementation:  We coordinate with your UK pension trustees, SIPP provider/trustee, US tax advisor and handle the transfer or consolidation.
   

Ongoing Planning:  We provide continuous support: portfolio monitoring, US tax/reporting guidance, withdrawal strategy aligned with your retirement income goals.

For US residents with UK pensions, the path forward is rarely straightforward, but with the right adviser you can navigate the complexities and position your retirement assets for clarity, flexibility, and compliance.

At Cameron James USA, we understand the unique cross-border landscape (UK pension rules + US tax/regulation) and we specialise in International SIPPs built for US residents.

If you’d like to review your UK pension holdings, explore whether an International SIPP is right for you, and receive transparent advice and implementation support, we’re here to help.Next Step: Book a discovery call with us today, receive a no-obligation review of your UK pension position and see how a SIPP designed for US residents could enhance your retirement-planning clarity and long-term outcomes.