Cross Border Tax Planning

SJB US provides cross-border tax planning services for foreign and dual nationals who reside in the United States. We work to help you understand the full cross-border tax planning issues to both US and non-US domiciled assets. We can provide help in all of the following areas:

  • Transfer of UK pensions into offshore SIPPs
  • Management of existing QROPS
  • 401k rollovers
  • IRAs
  • Trading accounts
  • Education plans

Our expertise can help you preserve, protect and grow your wealth so that its fully compliant in regard to the rules and regulations across different jurisdictions.

Foreign Account Tax Compliance (FATCA)

FATCA came into effect in 2014 and requires US taxpayers to disclose foreign accounts and offshore assets. The US Government has made it clear that’s its determined to recover the tax from all taxable assets. As such, hidden or unreported US assets can attract severe financial penalties.

It is common for individuals to have assets overseas, which means you will need to consider whether your assets are structured in a way that makes them consistent with the Foreign Account Tax Compliance Act (FATCA) as well as your personal financial goals.

Examples of investments that you might want to consider as tax inefficient in the US include Offshore Investment Bonds (which can be deemed as Passive Foreign Investment Companies or PFICs), QROPS and ISAs, which although favorable from a taxation perspective in the UK are considered toxic investments in the US.


If you have interest or signature authority in a foreign financial account which exceeds certain thresholds— including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account—the Bank Secrecy Act may require you to report the account annually to the Internal Revenue Service by filing a Report of Foreign Bank and Financial Accounts (FBAR).