I'm moving to the USA for a bit (so will be a US tax resident) and have a UK DC workplace pension, and I'm a little bit confused on what the reporting requirements are with the IRS. For clarity, by DC workplace pension I mean those in which an employer auto-enrolls you and to which the employer contributes some and you can contribute via salary sacrifice. I then invest the contributions in funds with the provider (in my case L&G).
Most issues I've seen seem to speak about SIPPs, leaving me a bit in the dark on vanilla workplace pensions. Some advice seems to suggest that moving to a SIPP would trigger additional filing requirements, which implies that leaving it alone would not, but I'd like to get some clarity/advice on what people are doing.
Obviously I need to file FBAR and 8938 (provided the amount is high enough).
I probably should file 8833 to claim deferral of gains under article 18 of the tax treaty, just to be safe.
But what about 3520 and substitute 3520A? I know there is a lot of discussion on whether this applies to SIPPs or not, and whether Revenue Procedure 2020-17 provides any relief. However, I've seen little discussion on whether a workplace pension would trigger these filing requirements. I don't even know if I'll be able to find enough information to complete a substitute 3520A.
Is a workplace pension structured as a trust in the UK? Would the IRS consider it a trust?
Fortunately, as I'll be living in the USA, I won't need to think about making contributions, and fortunately I'm long enough away from retirement that I don't need to think about distributions.