Author Topic: Uk implications of a U.S. Roth IRA conversion  (Read 7211 times)

s0198362

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Uk implications of a U.S. Roth IRA conversion
« on: July 01, 2024, 12:55:32 PM »
I posted this on the main Tax board but no bites.  Is there anyone active on the UK board who can provide any insight on my situation?

I am in the process or relocating to the UK at some point in 2024.
In 2025 I will not have a US salary.

What are the tax implications of converting some of my pretax 401K into my Roth IRA?
I imagine with careful conversions I should be able to keep myself below taxable income levels (or at least low).  However would this “income” be taxable in the UK?

Some extra info:  I am a dual UK and US citizen so will have to do tax returns for life.
I may (or may not) be eligible for a bonus in the U.S. for this tax year that gets paid in 2025.

I also will likely have US rental income (not huge amounts) as currently I am not planning to sell my home.

uk_american1

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Re: Uk implications of a U.S. Roth IRA conversion
« Reply #1 on: July 04, 2024, 01:08:06 PM »
I am in a similar boat, I am a dual US/UK citizen but located in the UK. I have UK rental income.

I converted traditional to Roth IRAs over the past few years. My UK/US accountant considered it as US earned income so I had checked with her in advance of how much I could move at a time so I split the task over multiple years. She handled it as taxed in the US but exempt in the UK, so it was only on my US return, not my UK one.

Once you are located in the UK (as a UK tax resident) the FEIE is very useful: https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion

I currently have a 3k/year capital loss carryover from some investments I sold which is used to offset ordinary income, so that also helped on the US front.

One other call out since you mentioned rentals: note the difference in the tax years, with the US year end on Dec 31 while the UK is on Apr 5 of the following year. For example I received a lump sum of rental income in the UK up front at the end of December for the following 6 months. It was UK earned income so it would have been taxed in the UK and then it wouldn't get taxed again in the US. However, as the US taxes are due first, it did not get taxed until my UK taxes were done after Apr of the following year so my accountant had me pay tax on it on the US taxes and then I had to pay again on the UK side. She pointed out she could do an amended return to get that back but her fees wouldn't really justify what I would finally save on it.

My old boss used to call this sort of stuff: paying the expat stupid tax. Sometimes you don't know what you don't know. Had the lump sum arrived in January it would have been fine.

s0198362

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Re: Uk implications of a U.S. Roth IRA conversion
« Reply #2 on: July 05, 2024, 12:59:57 PM »
Thank you uk_american1.

The double tax thing is certainly something I’ll need to be regularly with.  I’ll get a taxable relocation allowance paid in the UK when I arrive.  I may see if they can delay it by one month to January.  I will get “tax” prep paid for in my first year by my company, so that is perhaps useful to alert them of.


iangnu70

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Re: Uk implications of a U.S. Roth IRA conversion
« Reply #3 on: November 12, 2024, 10:46:37 AM »
I am also in a similar boat being a current USA resident who is moving across the pond to live back in the UK in retirement (55 yo). Dual UK/US citizen.

I have the usual taxation complications to figure out and a 401k trad that I’m looking to convert to ROTH to avoid higher taxation on any future withdrawals.

No income until I draw pensions in 2026, so looking to convert to Roth within US tax brackets in 2025 and beyond.

Happy to share my understanding / research and also happy to learn from others !

I’m also looking at suggestions for tax accountants !

Good luck to us :o)


jim555

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Re: Uk implications of a U.S. Roth IRA conversion
« Reply #4 on: November 23, 2024, 05:48:24 PM »
Another forum has a bit of info on this...

IRAs - again
https://talk.uk-yankee.com/index.php?topic=101402.0

Other threads also have so info on the topic.