FOR US CITIZENS LIVING IN THE UK
American in the UK? Your money answers to two tax systems at once.
You opened the ISA everyone recommended, and your UK adviser put you in funds that made sense at the time. Then you found out the IRS sees all of it differently.
N2 plans your UK financial life with the US rules in mind, and coordinates with your US tax adviser so the two sides fit together.
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It really is this complicated
The US taxes you on where you were born. The UK taxes you on where you live. Most financial products are built for one system or the other, never both. So the sensible move in one country becomes a penalty in the other. You did everything you were supposed to. The rules just weren't written with you in mind.
The traps that catch Americans in the UK
The ISA that isn't tax-free for you
In the UK an ISA grows tax-free. The IRS doesn't recognise the wrapper, so it usually taxes everything inside it. The "tax-free" account becomes one of the most expensive ones you own.
Funds that turn toxic across the Atlantic (PFICs)
Most UK funds, OEICs and investment trusts are treated by the IRS as PFICs. That means punitive tax rates and a separate IRS form for each holding, every year. Standard UK fund advice can quietly create a large US tax problem.
The 401(k) or IRA you left behind
Many US providers freeze accounts once you have a UK address. You can see the money, but you can't manage it or add to it. Your retirement savings end up stranded.
The bank or platform that turned you away (FATCA)
You went to open an account and got asked for a W-9, or got turned down altogether. UK firms often avoid US clients to sidestep FATCA reporting. It's common, and it isn't a reflection on you.
Paying tax twice, or fearing you will
Two tax systems with different deadlines and different rules for almost everything. Used correctly, the US-UK treaty stops you being taxed twice on the same income. Used carelessly, the mismatch costs you.
What happens to your estate, and your family
From April 2025 the UK taxes long-term residents on their worldwide estate. Layer that over US estate tax and the 1978 treaty, and a will that works in one country can fail in the other. Your family inherits the confusion.
A US person holding £100,000 of ordinary UK funds may owe a separate IRS form (Form 8621) for each fund, every year, whether or not anything was sold.
how we work
How N2 plans around the US rules.
Good planning starts with your life, not the tax code. Once we understand where you're heading, the structure is built to keep the US and the UK from working against each other.
Investments built to behave in both countries
Where it fits your plan, that means holding direct shares and bonds, or funds that carry the right reporting status, so your portfolio doesn't trigger PFIC treatment or punitive UK rules. The aim is a portfolio you can keep wherever life takes you.
Your UK plan and your US tax position, joined up
We plan your pensions, investments and allowances on the UK side, with a clear eye on how each decision lands with the IRS. Where you have a US tax adviser, we work directly with them so nothing falls between the two.
The two tax years, handled deliberately
The US runs on the calendar year, the UK from April to April. We plan around that mismatch so credits line up and you're not caught short at either deadline.
One plan for your whole life, not just your portfolio
Retirement on both sides, property, what you leave behind, a possible move back to the States. It all sits in one place, so the pieces work together.
Authorised and regulated by the Financial Conduct Authority
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What to expect when working with us
Financial planning with N2 follows a clear path — from an initial conversation to a written plan built around your life, and an ongoing relationship that keeps it on track as things change.
find out more01
Getting to know each other
02
Understanding your situation
03
Making sense of where you stand
04
Building your plan
05
Putting the plan into action
06
Reviewing life as it moves on
What our clients say
"Eugen delivered calm, professional guidance that gave me clarity and confidence. Eugen has a very good understanding of the US and UK legal and tax issues regarding international divorces and I now have a plan I trust and a much stronger sense of financial security."
— Verified client, Surrey
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"Eugen and team build a view on of our financial acumen and situation, and from there, provide guidance which is accessible (at our level) to us, practical, and considered in context of macro economic and political dynamics influencing long term investments."
— Verified client, London
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common questions
Questions Americans in the UK ask us
Can I open an ISA as a US citizen living in the UK?
You can open one under UK rules, but it rarely works in your favour. The IRS doesn't treat an ISA as tax-free, so it usually taxes the income and gains inside it, and the funds within are often PFICs, which makes the reporting heavy. For most US persons the ISA loses the advantage it's designed to give.
Why are my UK funds a problem for the IRS?
Most UK funds, unit trusts, OEICs and investment trusts fall under the US PFIC rules. PFICs are taxed at high rates and need a separate IRS form (Form 8621) for each holding, every year, whether or not you sold anything. It's one of the most common and expensive surprises for Americans investing through standard UK products.
What happens to my 401(k) or IRA now I live in the UK?
The accounts usually keep their tax-deferred status under the US-UK treaty, so moving doesn't trigger an immediate tax bill. The practical problem is access: some US providers restrict accounts held by people with an overseas address, which can leave you unable to manage or add to them. Planning here is mostly about access, drawdown and timing.
Can I move my US retirement account into a UK pension?
Generally no. HMRC doesn't recognise US plans like 401(k)s and IRAs as qualifying overseas pension schemes, so a direct transfer into a UK SIPP isn't available. Most people keep retirement savings in both countries and plan how they draw from each.
Does the US-UK treaty protect my 25% tax-free pension lump sum?
This is one to be careful with. The UK lets you take up to 25% of a pension tax-free, but the US generally still taxes that lump sum as income because of the treaty's saving clause. An amount that's tax-free on the UK side can be taxable on the US side, so it needs planning before you take it.
Why do UK banks and platforms turn away American customers?
To avoid the cost and risk of FATCA reporting, many UK firms simply don't take on US clients. Being asked for a W-9, or being turned down, is common and isn't a reflection on you. The work is finding providers and structures that will take you and keep you compliant on both sides.
Do I need a specialist, or will a normal UK adviser do?
A standard UK adviser will often recommend exactly the products that cause US tax problems, because they're planning for one system. US-aware advice on the UK side, coordinated with a US tax professional, is what keeps the two from working against each other.
Do you file my US and UK tax returns?
[Confirm to N2's model.] N2 plans your UK financial life with the US rules in mind and works alongside your US tax adviser, so the planning and the filing fit together. [If N2 does not file taxes: state plainly that tax return preparation is handled by your tax adviser and N2 coordinates with them.]
Do I need a US will and a UK will?
Often yes, and they have to be written so they don't cancel each other out. Since April 2025 the UK taxes long-term residents on their worldwide estate, which sits alongside US estate tax and the 1978 treaty. Estate planning across the two countries is technical and worth getting right early.
Is there a minimum I need to invest?
[N2 decision — see Section 7. Either state your minimum plainly, or say you work with people at different stages and the first call is about fit.]
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