Author Topic: US to UK financial terms translation guide  (Read 5783 times)

sea_saw

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US to UK financial terms translation guide
« on: January 10, 2018, 01:16:16 PM »
Right, I've had enough of just scrolling past MMM forum and reddit conversations that almost make sense but not quite.

As far as I've been able to work out:

  • 401(k) = pensions, often with employer contribution
  • IRA (or 'Traditional IRA') = Individual Retirement Account = SIPP
  • Roth IRAs and Roth 401(k) = approximately equivalent to an ISA

Any mistakes to correct here? Any more for any more?

I'm adding these to my FoxReplace FireFox addon (chrome has an equivalent). Generally used to make the internet more entertaining, but in this case I'll just add my helpful translation in brackets after the real thing.

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Re: US to UK financial terms translation guide
« Reply #1 on: January 10, 2018, 02:03:13 PM »
That’s better than I’ve ever done sea_saw. Based on that logic would a Mega Backdoor Roth be where you can somehow blow your allowance and invest a lot more? Hopefully in the next budget we’ll get a Tremendous Backdoor ISA.

I had worked out using some quite astounding powers of deduction:

Math = Maths
Honda Fit = Honda Jazz

It is interesting how different countries have different naming and approaches to things.

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sea_saw

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Re: US to UK financial terms translation guide
« Reply #2 on: January 10, 2018, 03:07:43 PM »
I think that's where you make contributions into a pension-typething (untaxed on the way in, supposed to be taxed as income when you draw on it) and gradually convert them into an ISA-typething (untaxed on the way out) so as to not pay tax in either direction.

I think as you say, it also gets around the equivalent of the ISA max annual contribution limit, as I gather the limit on new contributions doesn't apply to conversions (I guess a bit like turning a cash ISA into a S&S ISA).  Except I think while it's not capped it is taxed, thus doing it gradually in years of FIRE rather than freely while still employed.

I THINK (I'm going to continue sounding tentative until someone confirms or denies my accusations) that this is also known as a 'ladder'.

The exact differences between a backdoor, mega-backdoor, and super-duper-fragelistic-backdoor I have no idea. I've even just done a brief google for this post and given up. Maybe a more fluent speaker can help us.

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SwordGuy

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Re: US to UK financial terms translation guide
« Reply #3 on: January 10, 2018, 05:58:03 PM »
A 401K is NOT a pension.  A pension is a defined benefit plan, in effect, an annuity.  You pay in $x and receive $y a year at some time in the future.

A 401K is just a tax sheltered wrapper around an investment.  The investment might be individual stocks, or mutual funds, or bonds, or bond funds.  Possibly other things as well.   The tax sheltered wrapper has limitations on how much can be added to it in a given year and also has requirements to start pulling money out of the investment after one hits 70 1/2 in age.   

Most Americans using a 401K have one that is set up by their employer.  As such, it has a limited list of investment choices (sadly often with high fees).   The employer might add in additional funds but does not have to.

If someone owns their own business, as the employer of themselves, they can set up their own 401k plan and have their company toss money into it along with a portion of their salary from the company. 


AnswerIs42

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Re: US to UK financial terms translation guide
« Reply #4 on: January 10, 2018, 06:47:53 PM »
A 401K is NOT a pension.  A pension is a defined benefit plan, in effect, an annuity.

In the UK we use the term "pension" for both defined benefit plans and defined contribution plans. For DC plans, it is effectively just another tax wrapper. You don't have to buy an annuity with your DC pension pot any more, either.

sea_saw

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Re: US to UK financial terms translation guide
« Reply #5 on: January 11, 2018, 02:44:45 AM »
Ha! This is why translators need to have an even better command of the language they're translating into than the one they're translating from.

Thanks both for the clarification, that actually cleared up why I've seen people say pensions are not commonly available any more etc while describing holding what looked like a pension to me...

cerat0n1a

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Re: US to UK financial terms translation guide
« Reply #6 on: January 11, 2018, 02:56:10 AM »
A 401K is NOT a pension.  A pension is a defined benefit plan, in effect, an annuity.  You pay in $x and receive $y a year at some time in the future.

No. That's wrong - and a perfect example of why we need this thread. That may be what Americans mean by the word pension, but it's not how things work in the UK.

One type of pension in the UK is a defined benefit plan. Those mostly exist only in the public sector, or for people who worked for some private companies in the past - and the latter are not generally open to new entrants.

The more common kind of pension in the UK today is a defined contribution pension, which is pretty much how sea_saw described it and is analagous to a 401k. You put money in, free of tax, your employer also contributes some. That money gets invested (you typically get to choose where), but is not available until you reach some government mandated age (currently 57 for younger people, but has been creeping up over time.) There are various withdrawal options (you can take 25% as a lump sum, tax free) but in general, you pay tax on it on the way out. You can use that money to buy an annuity product, but relatively few people do today. The fact that US readers don't think that's a pension is irrelevant - it's what the law in the UK calls it and what the financial service industry calls it.

dreams_and_discoveries

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Re: US to UK financial terms translation guide
« Reply #7 on: January 11, 2018, 12:04:51 PM »
I like the idea, but I don't think many of the financial products across the countires  are directly comparable.

We've got such different tax and banking systems, there are some similarities but so many nuance and caveats it's going to be much more difficult than trunk=boot and pants=trousers.

PS I hate the pants thing. DuoLingo Chinese uses pants to describe trousers. It causes me frustration and laughter.

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Re: US to UK financial terms translation guide
« Reply #8 on: January 11, 2018, 02:00:09 PM »
The US concepts I've found the most alien are the nature of healthcare and at-will employment.

So US Healthcare = Wildly pricey essential expense which might just mean that a treatable medical condition doesn't kill you or bankrupt you.

UK Healthcare = The odd #10 for a prescription or 35p for a pack of Ibruprofen.

US emergency fund = the money that you spend to not be destitute when your employer cuts you for no reason.

UK emergency fund = the money that you spend to make unemployment more comfortable.

AnswerIs42

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Re: US to UK financial terms translation guide
« Reply #9 on: January 11, 2018, 03:25:45 PM »
Whenever I see the term, I think a "Mega Backdoor Roth" sounds like something one might expect to see in an adult movie.

seattlecyclone

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Re: US to UK financial terms translation guide
« Reply #10 on: January 11, 2018, 03:42:55 PM »
The exact differences between a backdoor, mega-backdoor, and super-duper-fragelistic-backdoor I have no idea. I've even just done a brief google for this post and given up. Maybe a more fluent speaker can help us.

If you must know...

A Roth IRA is an account where you can invest post-tax money for retirement. It grows free of investment income tax from then on, provided you meet the rules about withdrawal age and such.
The limit on contributions to these accounts is $5,500 per year, and people are only allowed to contribute to these if their income is below a certain limit ($120k if single, $189k if married).

But, there exists a loophole where those over the income limit can contribute their $5,500 to a different type of after-tax IRA (one in which any growth would be taxed at retirement, making it generally less appealing than a Roth IRA) and immediately move it into a Roth IRA. There are some caveats to this maneuver, but it basically renders the Roth IRA income limits moot. This maneuver is called the "backdoor Roth IRA."

There exists a further loophole where people with a well-crafted 401(k) scheme at their workplace can contribute a much larger amount of money (effectively $36.5k minus any employer contributions) to an after-tax portion of their 401(k) (roughly analogous to the after-tax IRA used in the backdoor Roth IRA maneuver) and immediately move that money to a Roth IRA. This is known as the "mega backdoor Roth."
« Last Edit: January 11, 2018, 03:47:11 PM by seattlecyclone »

daverobev

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Re: US to UK financial terms translation guide
« Reply #11 on: January 12, 2018, 07:17:40 AM »
@OP, I would just not worry about it. It doesn't translate easily because it just is not relevant; the only stuff that matters is "live within your means".

There is so much difference between countries (which makes me go bonkers when people say "need help in Europe" or similar). The UK has a relatively low state pension with very low yearly qualification to get your 'tick', amazing ISA room (and LISA), generally high house prices but that aside fairly low cost of living.

The US has insane healthcare costs, an amazing spread of cost of living possibilities (you can buy an acre of land for a few thousand dollars!!), a much more complex state pension...

Every state is different - some charge sales tax, some charge income tax, some give you free money for living there, some never let you go after living there.

sea_saw

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Re: US to UK financial terms translation guide
« Reply #12 on: January 12, 2018, 09:26:34 AM »
I'm not worried, or jealous, or hoping to apply US tax advice to the UK! Just curious, and enjoy being able to understand the things I scroll past :)

I've found for conversations on this forum or elsewhere on the web it actually is helpful to have a bit of a shorthand understanding of what some terms mean - they can often get used even in posts that aren't limited to US-specific financial maneuvers (which I obviously only have limited interest in).

Plus it's helpful to clear up different usages of the same words like 'pension', which are otherwise confusing.

@AnswerIs42 , I'm glad someone said it ;) Also, great name.

Kwill

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Re: US to UK financial terms translation guide
« Reply #13 on: January 13, 2018, 02:32:30 PM »
Thank you for starting the thread.

I still don't understand ISAs, and I think part of my trouble was I assumed they were like IRAs.

With ISAs, you don't have to wait until a certain age to take the money out, right? So why is it tax free? And how do ISAs pay so much more interest than regular savings accounts? Does contributing to an ISA reduce the amount of income you pay tax on in the year you contribute? Or is it only the interest on the account that comes in tax free?

Completely unrelated but what is MOT? Are there a lot of fees and difficulties around owning a car in the UK?

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Re: US to UK financial terms translation guide
« Reply #14 on: January 13, 2018, 02:52:59 PM »
ISA’s (Individual Savings Account) are tax free (£20000 per tax year) to encourage saving. However the money you can invest in them is post income tax deduction. So company pensions/SIPPS you save tax on the way in but are taxed on the way out, while ISA’s are tax free to take money out but income tax was charged beforehand.

You can invest in cash ISA’s which aren’t much different to normal savings accounts in terms of the interest rates available although you don’t pay tax on the interest. For non-ISA savings accounts 20% tax payers will pay tax on interest above £1000 in a tax year, while 40% tax payers can earn £500 interest before tax is charged.

On this board UK MMM’s will be investing in a stocks and shares ISA that allows us to invest in tracker and actively managed funds should they wish. There is now a LISA (Lifetime ISA) to further confuse things designed to help first time buyers get on the housing ladder.

An MOT is an annual test of vehicle safety and is about £55 for a regular sized car. I generally get my MOT at the same time as the car is serviced. That way it always passes.

Phew that was quite a test. Hopefully someone else will be along in a minute to correct all my mistakes!

sea_saw

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Re: US to UK financial terms translation guide
« Reply #15 on: January 13, 2018, 03:08:38 PM »
Clearly we need a UK to US translation guide!

An ISA is a tax-free savings account. You contribute to it from your net, post-tax pay. But once inside the ISA, money grows entirely tax free, and can be withdrawn entirely tax free, at any age.

You're totally correct, this is incredibly generous. They're intended to encourage saving.

There's a limit on how much you're allowed to contribute to an ISA per year, which is use-it-or-lose-it. The limit has grown immensely over the last few years, it's now a rather substantial £20k per person per year. So it's great for building up savings from your salary. (But you couldn't e.g. stuff an enormous inheritance into an ISA all at once, you'd have to feed it in over the years).

There are two different types of ISA accounts you can open, a cash ISA which will return a certain interest rate like a normal bank savings account would, and a 'stocks and shares' ISA, in which you can buy stocks/shares/funds.

I'm not sure what you mean about ISAs paying 'so much more interest than regular savings account'. Right now, cash interest rates are low, and cash ISAs are not generally beating high-interest bank accounts. Of course if you invest in the market in a S&S ISA you are likely to beat cash.

Does that all make sense?

I haven't covered LISAs ('lifetime ISAs') because, because. They're a newer offering and work a bit differently. They're intended specifically to help people save for their first home or for retirement. You can contribute up to £4k/year into a LISA, and the government will 'top it up' by 25%, so for every £4k you put into a LISA, the government will also contribute another £1k. If you access the money for anything other than a first-time house purchase or retirement, you lose the top-up bonus. Note that if you put £4k into an ISA, that counts as part of your £20k/year ISA allowance (so you'd only have £16k left to play with).

I've never owned a car so I'll let others take that - maybe easier to post a separate thread?

daverobev

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Re: US to UK financial terms translation guide
« Reply #16 on: January 13, 2018, 03:16:37 PM »
Canada has something similar to the ISA: The similarly poorly named TFSA, Tax Free Savings Account (which is also best used to invest in).

Unlike the ISA, if you take money out, you can put it back in the following year! So your contribution room = previous year's room - any contributions that year + any withdrawals + yearly increase.

Unlike the ISA, the yearly increase is only $5500 (indexed to inflation... but in $500 increments).

I'd LOVE to get an ISA. 20k a year now?? Holy crap.

Kwill

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Re: US to UK financial terms translation guide
« Reply #17 on: January 13, 2018, 03:33:41 PM »
Thank you for all the help! I am too old for a LISA, but it's good to know about the regular ISAs. I have been cautious about participating in anything other than ordinary bank accounts and my employer's pension scheme in the UK because having to file taxes in two countries confuses me. Also I am hoping to buy a place soon, but maybe next year.

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Re: US to UK financial terms translation guide
« Reply #18 on: January 13, 2018, 03:40:19 PM »
Crumbs yes that is confusing. I would definitely be seeking some specialist advice there Kwill or keeping it simple.

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Re: US to UK financial terms translation guide
« Reply #19 on: January 14, 2018, 01:05:18 AM »
My recollection is that ISAs are considerably less useful for people who also file US taxes - the US doesn't recognise them as tax-free, so you pay tax in the US on growth and dividends. (Not a professional anything.)

If you have an older crappier car, the annual MOT is a test that you dread because if it fails you can't drive the car or will have to have (often expensive) repairs. All the repairs are ones that should be made anyway, but I think other countries don't enforce the standards in the same way. Vehicle tax varies depending on how polluting the car is - some newer ones are free, mine is around #100 a year. The biggest difference in running a vehicle compared to the US would be the price of fuel. Driving tests are harder and a bigger deal than in the US.

dreams_and_discoveries

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Re: US to UK financial terms translation guide
« Reply #20 on: January 14, 2018, 04:08:24 AM »
And on the cars, manuals are the norm, not automatics.

cerat0n1a

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Re: US to UK financial terms translation guide
« Reply #21 on: January 14, 2018, 04:51:59 AM »
All the repairs are ones that should be made anyway, but I think other countries don't enforce the standards in the same way.
Most western countries have something similar. Australia has the "Rego" aka pink slip which is pretty similar to MOT.  France has the contrôle technique, Spain has the "itv"  and I think there was some talk of harmonising across Europe, certainly the UK MOT is now valid in France.

Don't know about the US, but some States (eg California) certainly require regular emissions checks on cars and I think there may be safety checks performed at the same time.


daverobev

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Re: US to UK financial terms translation guide
« Reply #22 on: January 14, 2018, 08:19:36 AM »
In the UK, people tend to - AFAIR - get their cars serviced at the same time as the MOT, so it's not usually all that bad. Oil change, check the lights, etc etc. The MOT was never that bad.

Compare to here - Ontario - you only have to get the car "safetied" when you sell it (or the buyer does, depending on how you want to do it, but either way when a new person buys a vehicle it needs checking before they can get the normal 1 or 2 year sticker). SOME parts of the province have a free emissions test. But other than that, if you have a ten year old, 15 year old vehicle with rust all over? No problem! Holes in the fenders (wings)? In the *floor*? Not going to be checked until you sell. Leaking oil? Exhaust? NO. PROBLEM. Just don't sell it. Or find a friendly mechanic that'll safety it even though it isn't safe...

Oh, and oil changes are recommended every 5000 km. 3000 miles in the US, generally. Eh. Harsher climate up here, to be sure.

daverobev

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Re: US to UK financial terms translation guide
« Reply #23 on: January 14, 2018, 08:23:12 AM »
Here's some more:

US & Canada: Tax return: Something most people have to do every year, telling the government mostly what they already know (at least that is true in Canada, it may be less true in the US? If you're reporting stuff from a 'slip' then I'd assume someone else has already told the government!).

In the UK, tax is withheld at source and adjusted by HMRC as you go - almost all of the time. A self employed person has to do a tax return but it is falling off a log simple (in comparison!).

In the UK there are allowances for all sorts of things and, if you are under them, you don't have to declare them or anything. Again, a reason that most people (90%? I don't know) *do not complete a tax return*.

PhilB

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Re: US to UK financial terms translation guide
« Reply #24 on: January 20, 2018, 10:56:23 AM »
Another significant difference is that the massive majority of people in the UK are paid monthly rather than two or four-weekly as seems to be common in the US.  I therefore have 9 paychecks to go!
We tend to get much more paid leave than in the US - 4 to 5 weeks pa, but the concept of sick leave is very different ie there isn't a fixed amount you can have each year whether sick or not.

shelivesthedream

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Re: US to UK financial terms translation guide
« Reply #25 on: January 21, 2018, 02:14:49 AM »
Here's some more:

US & Canada: Tax return: Something most people have to do every year, telling the government mostly what they already know (at least that is true in Canada, it may be less true in the US? If you're reporting stuff from a 'slip' then I'd assume someone else has already told the government!).

In the UK, tax is withheld at source and adjusted by HMRC as you go - almost all of the time. A self employed person has to do a tax return but it is falling off a log simple (in comparison!).

In the UK there are allowances for all sorts of things and, if you are under them, you don't have to declare them or anything. Again, a reason that most people (90%? I don't know) *do not complete a tax return*.

As a British self-employed person who does complete a tax return, I think that's almost true but not quite. Most British people are on PAYE which is taxed at source (I.e. Your employer sorts it all out for you and only ever gives you the post-tax money), and the vast majority of Brits will never have to complete a tax return. However, if you are self-employed or own a business then even if after all your deductions you don't earn enough money to be taxed, you still have to complete a tax return.

It's is pretty simple, though.

1. Do you fall into any of these special categories? (E.g. Farmer spreading harvest loss against multiple years)
2. How much did you earn?
3. What were your business expenses? (Would you like to list them individually or just tell us the overall number?)
4. Do you have vast stores of wealth giving you a firehose of investment income that we should be taxing?

Then they do the maths and tell you how much to pay and you can do it immediately by bank transfer. The only bit you really need to think about for most people is what counts as a business expense, and there's plenty on the Internet to tell you. And their phone line is staffed by cheerful northerners.

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Re: US to UK financial terms translation guide
« Reply #26 on: January 23, 2018, 04:27:13 AM »
Sounds like they were talking about the annual tax free allowance MmatoO - the amount anyone can earn before paying tax. It isn't limited to the construction industry.

AnswerIs42

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Re: US to UK financial terms translation guide
« Reply #27 on: January 23, 2018, 11:06:37 AM »
They could have been talking about the annual CGT allowance perhaps.

TacheTastic

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Re: US to UK financial terms translation guide
« Reply #28 on: January 27, 2018, 03:25:37 PM »

In the UK, tax is withheld at source and adjusted by HMRC as you go - almost all of the time. A self employed person has to do a tax return but it is falling off a log simple (in comparison!).

Unless you are me. When I went self employed, HMRC duplicated me on the system and gave me a bonus UTR (unique taxpayer reference).
Now as an employed student they have given me a split tax code, to divide my tax allowance between two jobs. I have only had one job for the last 16 months. Looking forward to a chunky rebate come April.

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Re: US to UK financial terms translation guide
« Reply #29 on: January 28, 2018, 04:30:27 AM »

In the UK, tax is withheld at source and adjusted by HMRC as you go - almost all of the time. A self employed person has to do a tax return but it is falling off a log simple (in comparison!).

Unless you are me. When I went self employed, HMRC duplicated me on the system and gave me a bonus UTR (unique taxpayer reference).
Now as an employed student they have given me a split tax code, to divide my tax allowance between two jobs. I have only had one job for the last 16 months. Looking forward to a chunky rebate come April.

Have you tried calling them and getting it sorted now? They can normally make these sorts of adjustments mid-year (you may be a special case though). Wait until a couple of days into February and call at 0745 for the best chance of getting through without an hour-long wait. Unless it suits you to give an interest-free loan to HMRC and not have access to the cash?

TacheTastic

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Re: US to UK financial terms translation guide
« Reply #30 on: January 28, 2018, 04:18:55 PM »
Have you tried calling them and getting it sorted now? They can normally make these sorts of adjustments mid-year (you may be a special case though). Wait until a couple of days into February and call at 0745 for the best chance of getting through without an hour-long wait. Unless it suits you to give an interest-free loan to HMRC and not have access to the cash?
It suits me. I can't touch it, but it will come back to me. It can't be invested, as I am still at the cash savings stage. The only interest rates I can currently access are rubbish. It is really no big deal for me, and less hassle than getting it back now on top of everything else I am currently dealing with.

 

Wow, a phone plan for fifteen bucks!