Yes, but you cannot transfer a UK pension directly into a US 401(k) or IRA. The most common route for UK expats in the US is to transfer into an international SIPP, which operates under UK pension rules but can hold multiple currencies and pay directly to a US bank account.
Since 2017, transferring a UK pension to a QROPS located outside your country of residence has triggered an Overseas Transfer Charge of 25%. For most US residents, an international SIPP is therefore a more tax-efficient structure than a QROPS in Malta or another offshore jurisdiction.
We see many clients in this situation. If your QROPS is in Malta or another offshore jurisdiction and you now live in the US, you may be paying higher fees than necessary and your original adviser may no longer be licensed to operate in the United States. We offer a complimentary review — get in touch and we will assess whether your current arrangement is still appropriate.
Not necessarily. Depending on the size of your pension, your retirement timeline, and your tax situation, leaving your UK pension in place may be the right decision. We will always give you an unbiased comparison of your options.
UK pension income is generally taxable in the US under the US-UK tax treaty. The specific treatment depends on the type of pension and your individual circumstances. We work alongside US tax advisers to ensure our clients understand the full picture before making any decisions.
Yes. A direct rollover from a 401(k) to a Traditional IRA is a common and tax-efficient move when changing jobs or leaving the US. If you have a Roth 401(k), it can roll into a Roth IRA. We can advise on which type of IRA is most appropriate for your circumstances.
You cannot transfer a US 401(k) into a UK pension scheme. Your options are to leave the funds in the US plan, roll them into an IRA, or (subject to penalties and tax) cash them out. Each has different implications for US and UK tax. We advise clients in exactly this situation.
Early withdrawals before age 59½ are generally subject to a 10% penalty plus income tax. There are exceptions — including the 'rule of 55' for employer plans if you have separated from service. We can help you understand your options before making any withdrawal decision.
No. While ISAs remain tax-free under UK rules, the IRS does not recognise the ISA tax-free status. Growth and income within an ISA is generally taxable in the US. This does not mean you must close your ISA, but it does mean you need to account for it correctly on your US tax returns.
A PFIC (Passive Foreign Investment Company) is a non-US fund or investment vehicle — including many UK unit trusts, OEICs, and investment bonds. US residents who own PFICs face complex and potentially punitive tax treatment. We work with clients to review their UK holdings and advise on the most tax-efficient approach.
Withdrawals from a US 401(k) are generally still subject to US federal income tax, regardless of where you live. Under the US-UK tax treaty, those withdrawals may also be taxable in the UK, though treaty provisions can limit double taxation. The exact treatment depends on the structure of your plan and your UK tax status.
Yes. You are not required to close or move your IRA. Many returning expats leave their US retirement accounts in place and manage them from the UK. You will need a US-licensed adviser who can continue to manage the account — which is what we provide.
Yes. US Social Security benefits can be paid to eligible recipients living in the UK. Under the US-UK tax treaty, Social Security payments to UK residents are generally only taxable in the UK, not the US. We can connect you with the right specialists to help you understand your entitlement.
You cannot move a 401(k) to a foreign pension scheme. Your options are to leave funds in the US plan, roll into an IRA, or withdraw (subject to penalty and tax). The right approach depends on your new country of residence and your tax situation in both jurisdictions.
This is one of the most complex situations we advise on. US citizens are taxed on worldwide income regardless of residence, while also being subject to UK tax as a UK resident. We help clients in this position structure their assets tax-efficiently across both systems.
Yes. You can leave it in your former employer's plan or roll it into an IRA. The right choice depends on the plan's fees, its investment options and your tax position in your new country. We help you compare both before you move anything.
If you're a US citizen, yes. Withdrawals from Traditional IRAs and 401(k)s stay subject to US federal income tax wherever you live. They may also be taxable in your country of residence, but most tax treaties stop you being fully taxed twice.
FBAR (FinCEN Form 114) applies to US persons whose foreign financial accounts total more than $10,000 at any point in the year. Most US expats with a local bank account have to file it. We don't file FBARs ourselves, but we build the obligation into your plan and can refer you to specialist US tax professionals.
Yes. The process is the same wherever you live. In a direct rollover the money goes straight to the IRA custodian, so nothing is withheld and there's no penalty. We handle the paperwork and coordination.
Usually, yes. Federal tax is withheld at source, typically 10% on IRA withdrawals and 20% on payments straight out of a 401(k). US citizens generally can't opt out of it at a foreign address. You may get some or all of it back through your US return and foreign tax credits, but you have to wait for it.
To a 401(k), generally only if you work for a US employer that offers the plan. To an IRA, you need earned income that's taxable in the US. If the Foreign Earned Income Exclusion removes all your foreign earnings, you may have nothing left that counts. Using foreign tax credits instead can keep you eligible.
Rolling a pre-tax 401(k) into a Traditional IRA is tax-free at the time; you pay tax when you withdraw. Converting to a Roth IRA is taxed in the year you convert, but future growth and qualified withdrawals are tax-free.
Yes. You can leave it in your former employer's plan or roll it into a US IRA, but you can't transfer it into a UK pension. We can manage your IRA from the US while you live in the UK.
Not automatically. The treaty has specific provisions for Roth IRAs held by UK residents, but how they apply depends on your circumstances. We advise clients on this regularly.
Yes. US citizens and green card holders file a federal return wherever they live. If you're abroad on the April deadline, you get an automatic extension to June 15 to file, but any tax due still accrues interest from April 15.
FBAR (FinCEN Form 114) is required if your non-US bank, brokerage and pension accounts together exceed $10,000 at any point in the year. It's filed online with FinCEN by April 15, with an automatic extension to October 15.
It reports foreign financial assets with your tax return. If you live abroad, the thresholds are $200,000 at year-end or $300,000 at any time if you're single, and $400,000 at year-end or $600,000 at any time if you're married filing jointly.
No. They don't go on either form. It's the accounts you hold in your new country that count, which is one more reason to keep your long-term retirement savings in the US.
Penalties for missed FBARs can run into thousands of dollars per account, even when no tax was owed. The IRS has streamlined procedures for catching up. Speak to a US tax professional before you file.
It moves money from a pre-tax account, a Traditional IRA or 401(k), into a Roth IRA. You pay income tax on the amount converted in that year. After that, growth and qualified withdrawals are tax-free, including for the people who inherit it.
If the Foreign Earned Income Exclusion or foreign tax credits bring your US taxable income down, you may pay little US tax on a conversion. The money then grows tax-free for the rest of your life.
No. Unlike Roth contributions, conversions have no income limit. Anyone can convert any amount; what you weigh up is the tax in the year you convert.
It depends on your country and its tax treaty with the US. We look at both sides, working with your local tax adviser where needed.
You cannot move a 401(k) to a foreign pension scheme. Your options are to leave funds in the US plan, roll into an IRA, or withdraw (subject to penalty and tax). The right approach depends on your new country of residence and your tax situation in both jurisdictions.
This is one of the most complex situations we advise on. US citizens are taxed on worldwide income regardless of residence, while also being subject to UK tax as a UK resident. We help clients in this position structure their assets tax-efficiently across both systems.
Many US custodians restrict or close accounts for non-US residents. That's their compliance policy, not a legal ban. Working with an adviser set up to manage accounts for non-US residents avoids the problem.
That depends on the rules in your country of residence. We'll confirm whether you're eligible before we recommend anything.
Yes, either directly from your employer's plan if it allows, or by rolling into an IRA first. The process is the same wherever you live.
An income rider is an optional feature, usually costing around 1% a year, that guarantees a set income for life regardless of markets. It's usually the main reason expats choose an FIA.
Nothing changes. It's a US contract held by a US institution, so your income carries on as before.
No. A variable annuity invests directly in funds and can fall in value. An FIA links growth to an index without investing in the market, and your principal is protected from losses.
A Fixed Index Annuity (FIA) is a contract with an insurance company that lets your money grow based on the performance of a market index — such as the S&P 500 — while protecting you from market losses. When the market goes up, you receive a portion of that growth. When the market goes down, your account value does not go down. Many FIAs also include an optional income rider that guarantees income for life, regardless of how long you live or what the market does.
No. A variable annuity invests directly in sub-accounts similar to mutual funds, meaning your account value can decline in a down market. A Fixed Index Annuity does not invest directly in the market — your principal is protected from market losses. Growth is linked to an index, but you are not directly exposed to market risk.
Your principal is protected from market losses. However, FIAs are not FDIC-insured bank accounts. Their guarantees are backed by the financial strength of the issuing insurance company, which is why we only work with highly-rated carriers. Early withdrawals during the surrender period may incur a charge.
A guaranteed income rider is an optional feature — added to an FIA for an additional annual fee (typically 0.95%–1.25%) — that guarantees a specific level of monthly or annual income for the rest of your life, regardless of market performance or how long you live. It effectively creates a personal pension from your savings.
Most FIA contracts have a minimum premium of $20,000–$50,000. They work best as part of a broader retirement income strategy — typically allocated to money you want to protect and use for predictable income, rather than funds you may need liquid access to in the short term.
