Who this is for
- Americans with UK SIPPs
- US persons auto-enrolled into workplace pensions
- Clients approaching UK pension drawdown
Pensions & Investments
UK pension tax planning
How SIPPs and workplace pensions are treated under US law and the US-UK treaty — contributions, growth, and distributions.
Overview
Why this filing matters
How SIPPs and workplace pensions are treated under US law and the US-UK treaty — contributions, growth, and distributions.
Note — SIPP, workplace pension — US treatment.
What you get
- US tax treatment analysis
- Treaty position (Form 8833) where appropriate
- 3520 analysis for certain trust-like arrangements
Our approach
Built for the cross-border edge cases.
Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.
We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.
- Position memo on every meaningful election, with the reasoning written down for the next return
- Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
- Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Our process
How we handle your uk pension tax planning
Four steps from first call to filed return. Fixed fee confirmed before any work begins.
- 01
Intake
30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.
- 02
Review
We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.
- 03
Prepare
Draft returns and schedules are prepared with plain-English commentary on key positions for your review.
- 04
File
E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.
Pricing
Fixed fees — no surprises
UK pension analysis: £350 + VAT for a single-plan review; £600 + VAT for multi-plan or pre-retirement drawdown planning. Bundled free with comprehensive tax return engagements.
FAQs
Common questions about UK pension tax planning
Is my SIPP taxed by the US while it grows?
Generally no — the US-UK treaty (Article 18) lets most SIPPs grow tax-deferred in the US for employer-sponsored and certain personal pension types. Some exotic structures need case-by-case analysis.
Do I need to report my SIPP on 3520 or 8938?
8938 usually yes if over threshold. 3520/3520A is contested — recent IRS guidance (Rev. Proc. 2020-17) exempts most employer-sponsored and tax-favoured foreign retirement trusts, but borderline plans may still need filings.
What happens when I take a lump sum?
The 25% UK tax-free lump sum is not automatically tax-free for US purposes. Treaty position under Article 17(2), plan type, and timing all matter — and getting it wrong can trigger ordinary-income treatment in the US on a meaningful amount.
Can I contribute to a SIPP while living in the US?
Contributions are technically possible but often inadvisable — UK tax relief only applies with UK-source earned income, and US treatment of the contribution can be suboptimal. We'd usually recommend pausing UK contributions during US residency.
My workplace pension auto-enrolled me — what now?
Usually fine. Contributions get US treatment analysed (often excludable under the treaty); growth is tax-deferred; distributions are taxed when taken. We map out any ongoing filings and confirm treaty coverage at intake.
Ready to get this filed?
Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.