Investment Review

How to Build a Financial Plan That Spans the Atlantic

UK and U.S. pension, tax and estate rules rarely work smoothly together. In this guide, Tom Pewtress breaks down how to create one co-ordinated plan that works across both systems.

Last Updated On:
December 9, 2025
About 5 min. read
Written By
Tom Pewtress
Head of USA and Private Wealth Partner
Written By
Tom Pewtress
Head of USA and Private Wealth Partner
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At Skybound Wealth USA, my work centres on helping clients align their wealth, tax responsibilities, and long-term plans across both countries. Whether you intend to stay permanently, return to the UK, or remain undecided, having a strategy that works on both sides of the Atlantic is essential.

Here’s how I advise clients to approach it.

Different Tax Years, Different Reporting. One Global Income

The UK tax year runs from 6 April to 5 April, while the U.S. follows the calendar year. This mismatch alone is enough to trip people up. On top of that, U.S. tax residents face worldwide income reporting, FATCA and FBAR filings for foreign accounts, and PFIC rules around non-U.S. funds. Even your UK pension, though growing tax-deferred at home, must be reported in the U.S.

Planning tip: Work with an accountant who understands both systems, and build a financial plan that ensures pensions, investments, and property income are declared and structured efficiently across jurisdictions.

Retirement Planning: Bridging SIPPs, 401(k)s, and IRAs

Many clients hold UK pensions alongside U.S. retirement plans such as a 401(k) or IRA. Each works differently. UK schemes grow tax-deferred but withdrawals are taxable in the U.S., while 401(k) contributions reduce U.S. taxable income but don’t benefit from UK relief. The U.S.–UK tax treaty offers solutions, but it must be applied correctly.

Planning tip: Map out your retirement assets together, not in isolation. Understand which pots to draw from first, how income will be taxed, and the role timing plays in maximising value.

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Property in One Country, Income in Another

Owning property across borders brings further complexity. Rental income from a UK buy-to-let must be reported in the U.S., while selling a UK home may qualify for UK relief but not for U.S. exclusions. Conversely, U.S. property sales may trigger depreciation recapture, which doesn’t exist under UK rules.

Planning tip: Review property transactions through both tax lenses. The timing of a sale and exchange rate movements can have a major impact on the outcome.

Estate Planning: Two Legal Systems, One Global Legacy

Cross-border estates require careful coordination. U.S. estate tax rules currently allow for a $13 million exemption, set to reduce in 2026, while UK inheritance tax applies at 40% above £325,000. Recent UK changes replacing domicile of origin with a residency test add another layer, and pensions remain within the UK inheritance tax net regardless of residency.

Planning tip: Align your wills across both countries, appoint executors who understand the cross-border context, and ensure beneficiary designations match the legal frameworks that apply.

Why a U.S.-Only or UK-Only Adviser Isn’t Enough

Too often, expats rely on advisers who understand just one jurisdiction. The result is a patchwork approach: compliant in one country but exposed in the other, efficient in one area but leaking value elsewhere. Estate and pension rules rarely align.

At Skybound Wealth USA, our proposition is designed to bridge that gap. We work with U.S. tax professionals and UK trustees to ensure your financial plan works as a single, coordinated strategy.

Protecting Your Wealth Across Borders Starts Here

You don’t need two separate plans. What you need is one joined-up strategy that protects you across borders. That means understanding when to draw pension income, balancing taxable and tax-deferred assets, reducing global tax liability, aligning estate documents and beneficiary nominations, and building an investment plan that meets U.S. rules while remaining globally efficient.

If you would like to review how your U.S. and UK finances fit together, book a cross-border planning review. The right advice today can give you clarity and confidence for the future.

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Written By
Tom Pewtress
Head of USA and Private Wealth Partner

Tom Pewtress is a fee-based fiduciary adviser and Head of USA at Skybound Wealth USA. He helps U.S. citizens, dual-nationals and internationally mobile families manage their financial lives across borders. Tom specialises in U.S. retirement accounts, 401(k) and IRA decisions, Roth strategies, tax-aware investing and long-term planning for globally mobile households.

Disclosure

Past performance is not a guide to future returns. Investment in securities involves the risk of loss and the advice herein cannot be construed as a guarantee that future performance will be reflective of past returns.

Book A Call With Tom Pewtress Today

Managing UK and U.S. finances separately leads to gaps, duplicated tax, and lost planning opportunities. A joined-up approach protects wealth across both systems.

A conversation with Tom Pewtress at Skybound Wealth USA can help you:

  • Coordinate SIPPs, 401(k)s & IRAs under one plan
  • Avoid double reporting issues, PFIC exposure & filing traps
  • Review UK property taxation from a U.S. perspective
  • Align wills, beneficiaries & estate documents cross-border
  • Build a long-term structure whether you stay or return home

Book A Call With Tom

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