SIPP/ISA for US/UK dual citizen (UK resident)
SIPP/ISA for US/UK dual citizen (UK resident)
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jimmybell

Original Poster:

680 posts

137 months

Thursday 23rd October
quotequote all
My better half was born in the US. Never lived there after 2yo, but has dual citizenship. In some ways a nice thing to one day utilise, maybe. In others - a level of life admin i could do without.

She has a work Pension via Aegon. We’d like to move that somewhere useful (SIPP), and ideally open an ISA alongside it.

The question is to confirm what kind of investment vehicles she can utilise, with what providers, and what limitations exist.

I’ve done a bunch of reading but i’m not confident in what i’ve read.

ISA: I’ve seen mixed commentary on ISAs. Some say you cant have them as not recognised as tax free by IRS. others say it’s fine as long as you don’t buy PFICs (thus stuff like VTI/VOO instead of VUAG, etc). Perhaps it’s a mixx.. having one is fine but not tax free?

SIPP: i think this should be fine, seemingly IRS recognises UK pensions as a valid tax wrapper. Guessing PFIC thing may apply?

Providers: some suggestion that IBKR, HL maybe fine. If whatever platform could host both accounts under one login that’d be a plus but not essential. Likelyhood here is simply holding S&P ETF in both with regular contributions to max allowances.

If anyone has experience, or pointers - would be greatly appreciated! Missing out on a bunch of potential tax relief here.