Hey there,
I am a UK citizen, US resident with green card. File all my Fbars etc. I have 2 SIPPS in the UK, but do not pay tax in the UK (about be issued an NT code).
My question concerns passing my SIPPs onto my children as part of my will. My children are US citizens and no ties to UK.
I understand there are two scenarios in the UK:
I pass before 75, in which case all SIPP assets are passed to my heirs tax free from a UK perspective. How would the US treat this RE my children? Is this covered by the treaty or would they be taxed on the income?
I pass after 75, in which case the SIPP is taxable in the UK, but as I have an NT tax code and my children won't have a UK tax code, how are the SIPPs passed on in this situation?
Thanks guys,
A
