A simple question—can a UK pension be rolled into a US IRA or 401(k)?—opens a door to some of the most punishing rules in cross‑border retirement planning. We walk through the hard stop that HMRC’s QROPS regime creates, why no US plans qualify, and how an “unauthorized payment” can unleash a 55% UK charge that vaporizes decades of savings. Then we pressure-test the popular third‑country workaround, showing how the 25% overseas transfer charge, US income tax, and foreign trust reporting can tu...
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A simple question—can a UK pension be rolled into a US IRA or 401(k)?—opens a door to some of the most punishing rules in cross‑border retirement planning. We walk through the hard stop that HMRC’s QROPS regime creates, why no US plans qualify, and how an “unauthorized payment” can unleash a 55% UK charge that vaporizes decades of savings. Then we pressure-test the popular third‑country workaround, showing how the 25% overseas transfer charge, US income tax, and foreign trust reporting can tu...
Beyond Borders: Protecting Your Legacy as a US Expat in France
The Expat Sage Podcast
28 minutes
2 months ago
Beyond Borders: Protecting Your Legacy as a US Expat in France
Franco-American inheritance planning presents a complex web of conflicting tax systems and legal principles that can significantly impact expatriates' legacies without proper planning. • French inheritance tax focuses on beneficiaries, with tax rates varying dramatically based on relationship (0% for spouses, up to 60% for unrelated beneficiaries) • US maintains citizenship-based taxation, claiming worldwide assets regardless of residency • French forced heirship rules legally reserve portio...
The Expat Sage Podcast
A simple question—can a UK pension be rolled into a US IRA or 401(k)?—opens a door to some of the most punishing rules in cross‑border retirement planning. We walk through the hard stop that HMRC’s QROPS regime creates, why no US plans qualify, and how an “unauthorized payment” can unleash a 55% UK charge that vaporizes decades of savings. Then we pressure-test the popular third‑country workaround, showing how the 25% overseas transfer charge, US income tax, and foreign trust reporting can tu...
