Financial Advisor with taxation expertise

Hello,

Does anyone have a recommendation for a financial advisor with expertise in US & UK taxation? I am not looking for someone to advise me on WHAT to invest in, but rather to advise me on HOW to invest (SIPP / pension / Roth / ISA / etc.) to optimize taxation.

Thank you in advance for any recommendations.

I really like Thun Financial. Their website has great articles and webinars too.

Hello,

Does anyone have a recommendation for a financial advisor with expertise in US & UK taxation? I am not looking for someone to advise me on WHAT to invest in, but rather to advise me on HOW to invest (SIPP / pension / Roth / ISA / etc.) to optimize taxation.

Thank you in advance for any recommendations.

There are a couple of specialist firms, but suitably qualified people are rare.

WHAT you invest in is key to HOW you invest to minimize tax issues. If you are a US citizen resident in the UK a ROTH is fantastic as is a UK employer pension. The tax efficiency of a SIPP is debated and for an ISA invest in a cash ISA and/or individual stocks and shares unless you have access to a US stock fund that is also UK reporting.

Thank you for the input, and apologies for being unclear.

I would like to pay someone to help me determine what account types are most tax-efficient for my situation, maybe putting together a financial plan. However, I am not interested at this point in someone actually managing my investments. Does that make sense and does such a service exist?

Thank you for the input, and apologies for being unclear.

I would like to pay someone to help me determine what account types are most tax-efficient for my situation, maybe putting together a financial plan. However, I am not interested at this point in someone actually managing my investments. Does that make sense and does such a service exist?

A tax specialist can advise on tax efficient investments, but if you describe your situation I'm sure a few folks on here will offer opinions.

IMHO the first place to start is by being tax efficient where you live and then see if that efficiency translates to the US. You have tax efficient accounts and also tax efficient funds.

So in the UK your first tax efficient account would be a UK employer pension as that will also be US tax efficient. If you can fund a ROTH that also had tax advantages in both the US and the UK.

ISAs do not get any special US tax advantages as the IRS does not recognize the ISA wrapper and will simply tax what's in the ISA account.

There are also tax efficient ways of investing in a regular investment/brokerage account, but you must be sure that the investment dividends and gains are treated as such in both the US and the UK and not taxed as income by either. Then you can make use of capital gains allowances and deductions to limit your tax bill.

Hello O Bojarski, 

If I researched you right, you're from Atlanta originally, Possibly you want a fee-only planner in the USA sense, which requires the planner to take fees only directly from clients. Almost all IFAs in the UK accept money from life companies and banks, and indeed take their 2% - 3% charge from the investment of new money - so you'd exclude them. Then you also have another two constraints - a planner with UK and US tax competence.

Thun - mentioned in this thread - are not authorised in the UK as far as I can telll from the FCA register. I too admire their website, don't agree with some of their conclusions because (1) there's no point in analysing tax unless you also analyse charges and (2) their solutions oblige one to use a US broker who is not willing to place trades, for instance, in Hong Kong or Mumbai. They're a good firm, but it's difficult to see how you can get advice from them legally on European soil.

Without meaning to say this with overtones of pride, or self-importance, I think I am the only fee-only planner authorised by the FCA, understanding UK and US tax with the qualifications you want. There may be others. You can start to look on the CFP Board planner search - search for those in the UK, or London. Last time I looked there were three. Then you can go through the Chartered Inst. of Tax site for a tax qualified person also on the other list.

I'm happy to advise without pitching for asset management. You're welcome to contact me with a private message. I don't want to talk about our services here because forum members are good enough to give their time and know-how freely and I respect that and want to support this forum's culture.

I'll start by saying robnw is a known and sincere contributor to this site, so his comments above should viewed as those of a knowledgeable individual on this subject.

robnw may correct me where I'll most likely be wrong with the following comments, but a brief back to basics on financial advice in the UK:

Does the OP understand the important difference, in the UK, between financial guidance and financial advice? Does the OP understand the role of the Independent financial advisor (IFA)?

If the OP is seeking financial advice, it's worth knowing all financial advisors must meet certain expertise criteria, have SPS certification, and be registered with the FCA (and don't be afraid to ask).

http://www.cii.co.uk/membership/obtain-your-sps/

Finding someone who meets all the requirements above, plus is fully knowledgeable on all aspects of investing (including property or many other types of investment choices, for example) in the UK, plus understands the tax consequences of such investing for both the UK and US, plus offers independent advice NOT restricted to selected products, will be a rare bird indeed! 

Finding someone who meets all the requirements above, plus is fully knowledgeable on all aspects of investing (including property or many other types of investment choices, for example) in the UK, plus understands the tax consequences of such investing for both the UK and US, plus offers independent advice NOT restricted to selected products, will be a rare bird indeed!

+1. If the OP would describe their situation and what they want to achieve we can offer some opinions. Are they looking to save for retirement, a rainy day, and are they planning to move back to the US some day?

My advice to any US citizen moving to the UK would be to do a spring cleaning of their finances and to set up a Vanguard brokerage account. This will avoid the high fees that are so common in the UK and allow them to buy US Vanguard EFTs which are not PFICs and are also HMRC reporting. Combine those with a ROTH and a UK pension fund and you have a good start.

But you have to have a US address with Vanguard, right? Wouldn't this involve being a bit sneaky about where you actually live?

I plan to buy Vanguard ETFs through Charles Schwab.

You have to have a US address to open a Vanguard account, but you don't need one to buy ETFs etc


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Thank you much for all the advice and sorry for the late response. I am moving within the UK in a few weeks so it has been hectic!

+1. If the OP would describe their situation and what they want to achieve we can offer some opinions. Are they looking to save for retirement, a rainy day, and are they planning to move back to the US some day?

I am looking to save for retirement as I already have a rainy day fund in a money market account.
I do expect retirement to be in the US so it is uncertain whether I will move back there in 2 years or 20 years at this point.

My advice to any US citizen moving to the UK would be to do a spring cleaning of their finances and to set up a Vanguard brokerage account. This will avoid the high fees that are so common in the UK and allow them to buy US Vanguard EFTs which are not PFICs and are also HMRC reporting. Combine those with a ROTH and a UK pension fund and you have a good start.

OK, so to summarize the best mechanisms to save for retirement in order of preference for a US citizen living in the UK:
1. UK Pension (including employer matching)
2. US Roth IRA
3.
What about after that? If I am not eligible for investing in a Roth IRA, what should be next? I have an account with Interactive Brokers invested in Vanguard ETFs, but is there no opportunity to invest in ISA/SIPP to get some form of tax benefit?

Are there any accounts/mechanisms other than standard brokerage accounts that I could use to save for my 1-year old daughter's future?

Again, thank you for all the input.

A UK employer pension is a good way to save. You get free money from the employer match and the pension wrapper will protect you from PFIC issues as the treaty allows any gains in a DC pension to be exempted from US tax while you are saving. Contributions will be UK tax deferred and on the US tax side you can ether defer tax by using the treaty or pay the tax upfront with FTCs or exclude you contributions from US tax using FTC.....remember you cannot use FEIE for your employer's contributions.

If you have a US based investment account contributing to a ROTH is great. You do that after tax, but all gains and withdrawals are US and UK tax free as long as you follow the ROTH rules.

After that, if you've been sensible enough to open a US based investment account while you had a US address you can buy funds that a both US based and HMRC reporting; Vanguard ETFs are the obvious choice. If you can buy those in a UK account that would be tax efficient in the US and the UK as well. But never buy a non-US domiciled fund as those will get you into PFIC trouble. You can buy individual stocks and shares in either a US or UK brokerage account and not have any nasty tax consequences (ie no PFIC issues), but the annual reporting might get a bit tricky.

The only ISA you should ever consider is a CASH ISA, again stocks and shares ISAs will get you into PFIC trouble, but the interest on a CASH ISA will be taxed in the US.

The SIPP is a continuing bone of contention. If it's classed as a pension for treaty purposes then there is no problem, if not the recurring PFIC and foreign trust issues arise.

I have been told thatwhen we contribute to a UK pension, the government will top it up 20%.