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Pensions & retirement
UK pensions under US rules, 401(k)s and IRAs under UK rules, lump sums and the treaty positions that hold them together.
Pensions that cross the Atlantic without losing their shelter.
A pension built in one country and drawn in the other is where the two systems disagree most. The tax-free lump sum, employer contributions, Roth conversions — each is treated differently depending on which side is asking.
Decisions made at drawdown are hard to unwind, so the modelling belongs before the election.
What we do
01
UK pensions for US persons
How workplace and personal pensions are treated by the IRS, including growth and employer contributions.
02
US plans for UK residents
401(k), IRA and Roth treatment under UK rules, and what a distribution actually costs.
03
Lump sums
Whether the UK tax-free lump sum survives contact with the US system, and how to take it if not.
04
Drawdown sequencing
Which pot to draw first, given two tax systems and two sets of allowances.
Why us
Modelled before the election
Most pension decisions are one-way. The lump sum is taken once, the conversion happens once.
We model the cross-border outcome first, so the choice is made on numbers rather than assumption.
When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.
View our peopleFrequently asked
Is my UK tax-free lump sum tax-free in the US?
Not automatically, and the treatment turns on the treaty position and how the payment is structured. It is one of the most common places people are caught out.
Should I transfer my pension before moving?
Sometimes, but transfers can trigger charges and close options. It deserves modelling rather than a rule of thumb.
Are my UK pension contributions deductible in the US?
Sometimes, via the treaty and depending on the scheme and your circumstances. Employer schemes and personal pensions are not treated identically.
Is growth inside a SIPP taxable to the IRS annually?
It depends on the treaty analysis and the scheme's classification. The position taken should be consistent year to year, which matters more than most people realise.
Do I report my pension on FBAR or 8938?
Frequently both, depending on the type and value. Pensions are among the most commonly missed reportable assets.
How are drawdowns taxed if I live in the US?
The treaty generally allocates periodic payments to the country of residence, with distinct treatment for lump sums. The manner of drawing changes the answer.
UK pensions under US rules, 401(k)s and IRAs under UK rules, lump sums and the treaty positions that hold them together.
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