Client moving from the US to the UK
A move from the US to the UK can leave a client with retirement accounts, investments and tax obligations spanning two financial systems.
401(k)s, Traditional IRAs, Roth IRAs, US brokerage accounts, Social Security and other US assets may all remain relevant after UK residence begins.
Josh Clancey works alongside US CPAs, UK tax advisers, lawyers and other professionals where a move from the US to the UK creates wider financial-planning decisions around retirement accounts, investments and long-term wealth.
The US accounts do not disappear when the client leaves
Clients often arrive in the UK with substantial assets still held in the US.
Those may include:
- 401(k) plans
- Traditional IRAs
- Roth IRAs
- US brokerage accounts
- employer shares
- deferred compensation
- cash
- 529 plans
- Social Security entitlement
The first question is not necessarily whether these assets should be moved.
It is how each account will be treated once the client becomes UK resident and how it fits into the client's wider UK financial plan.
US and UK tax advisers should establish the relevant tax position before restructuring or withdrawals take place.
Common planning areas when a client moves from the US to the UK
401(k) accounts
The client may be able to retain an existing 401(k) after leaving the US rather than immediately rolling it over or withdrawing it.
The decision should consider the plan's investment options, charges, access, administration and the client's wider retirement strategy.
Traditional and Roth IRAs
IRA and Roth IRA accounts can remain important long-term retirement assets after the client becomes UK resident.
Cross-border tax treatment should be established before contributions, conversions, withdrawals or restructuring are considered.
US brokerage accounts
Some US institutions restrict the services they provide when an account holder becomes resident overseas.
Custody, investment availability and future account access therefore need to be reviewed.
The UK FIG regime
Some clients becoming UK resident after a sufficiently long period of non-UK residence may qualify for the four-year Foreign Income and Gains regime.
Retirement assets in both countries
The client may ultimately depend on UK pensions, US retirement accounts, Social Security, the UK State Pension and personally held investments.
Mixed US and non-US families
The client may be a US citizen while their spouse or beneficiaries are not.
That can create additional investment, estate and beneficiary-planning considerations.
Questions to ask before the client moves
Which US retirement accounts does the client hold?
401(k)s, Traditional IRAs and Roth IRAs should be identified separately rather than treated as one pool of retirement money.
Can the existing US providers continue to service the client?
The answer may depend on the institution and the client's new country of residence.
Does the client expect to remain a US taxpayer?
Citizenship, Green Card status and other circumstances may mean US filing obligations continue after the move.
Is the client potentially eligible for the UK FIG regime?
Eligibility depends on the client's previous UK residence history and should be established by the appropriate tax adviser.
What US investments will remain outside retirement accounts?
Brokerage holdings may need to be reviewed for UK tax efficiency and practical custody.
Is the client likely to retire permanently in the UK?
Future spending currency and residence should influence how the overall retirement portfolio is constructed.
Does the family contain both US and non-US persons?
This can affect investments, beneficiaries and estate planning.
Useful resources for advisers working with US-to-UK clients
The Professional Adviser's Guide to US Clients Moving to the UK
A broad guide to the main financial-planning issues that can arise before and after a client's move from the US to the UK.
UK Returners With 401(k), IRA or Roth IRA Accounts
A focused technical brief for clients returning to or becoming resident in the UK while retaining US retirement assets.
401(k) Planning for Clients Living Outside the US
A technical resource covering the wider planning considerations around retaining a US workplace retirement account overseas.
IRA and Roth IRA Planning After Leaving the US
A practitioner-focused resource covering Traditional and Roth IRA planning for internationally resident clients.
US Brokerage Accounts When Clients Move Overseas
A technical brief covering custody and investment considerations when a US investment account holder relocates internationally.
The Professional Adviser's Guide to UK Residence, the FIG Regime and Inheritance Tax
A wider guide to the UK residence and tax framework that may become relevant after the move.
The FIG regime may be relevant to some US-to-UK movers
From 6 April 2025, qualifying new UK residents can potentially claim relief under the Foreign Income and Gains regime.
Broadly, eligibility requires the individual to be within their first four tax years of UK residence following at least 10 consecutive tax years of non-UK residence.
Relief is claimed rather than automatic.
The client can choose which qualifying foreign income and gains to claim relief on, but claiming FIG relief can also affect access to certain UK allowances.
For an eligible US-to-UK client with substantial US investments, this can materially affect the planning during the first years of UK residence.
The UK tax adviser should determine eligibility and advise on the claim.
Josh can then incorporate that position into the investment, cash-flow and retirement strategy.
US retirement accounts need coordinated UK and US advice
Moving to the UK does not automatically mean a 401(k) or IRA should be withdrawn, transferred or consolidated.
The client may have valuable retirement assets accumulated under the US system that remain appropriate to hold there.
The planning should consider:
- account type
- available investments
- provider restrictions
- charges
- withdrawal rules
- expected retirement age
- beneficiary arrangements
- UK tax treatment
- continuing US tax treatment
- other UK and international assets
The US-UK tax treaty can be relevant to pension and retirement-account taxation, but the treatment depends on the account and transaction being considered.
That is particularly important before Roth conversions, distributions or other changes are made.
The relevant US and UK tax advisers should establish the tax position first.
When should the referral happen?
Ideally, before the client becomes UK resident.
That provides time to review:
401(k)s
Traditional and Roth IRAs
US brokerage accounts
existing investments
expected UK residence
potential FIG eligibility
beneficiaries
long-term retirement location
The client does not necessarily need to move their US assets.
The objective is to establish what can stay, what may need changing and how everything will work together after the move.