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Foreign Pension Reporting Guide

US tax treatment and reporting requirements for foreign pensions — UK SIPP, Australian Super, Canadian RRSP, and more

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Click your pension/country for specific reporting guidance:

🇬🇧 UK SIPP / Occupational Pension / State Pension

Treaty applicable?Yes — US-UK Treaty Art.17/17A
Private pension taxationResidence country only (Art.17)
Government pension (NHS, Civil Service)Source (UK) only — unless US citizen
UK State Pension taxationResidence country only
FBAR reporting of SIPPRequired if >$10k aggregate
Form 8938 reportingIf above FATCA thresholds
Form 8833 required?Yes — to claim treaty position
Form 3520/3520-A?Generally NO — SIPP is pension trust exception

⚠️ Key Issue: Lump sum PCLS (25% tax-free cash) — the IRS may tax this even if UK treats it as tax-free. Treaty Art.17(2) may apply. Get specific advice on lump sum treatment.

🇦🇺 Australian Superannuation

Treaty applicable?Partially — US-AU Treaty 1982
IRS position on SuperOften taxable annually in US
FBAR reportingRequired if >$10k
Form 8938If above FATCA thresholds
Form 3520 (foreign trust)?Possibly — actively debated
Form 8833 recommended?Yes — to assert treaty position

⚠️ Major Issue: Australian Super's US tax treatment is highly contested. The IRS has no formal ruling. Some advisors argue treaty protection applies (as pension); others say annual earnings are taxable. Highly recommend specialist advice.

🇨🇦 Canadian RRSP / RRIF

Treaty applicable?Yes — US-Canada Treaty Art.XVIII bis
Growth deferral in US?Yes — treaty allows deferral until distribution
FBAR reportingRequired if >$10k
Annual election needed?Yes — Form 8891 (now defunct) → attach to return
TFSA (Tax-Free Savings)NOT exempt — taxed annually in US
CPP / OAS taxationUp to 85% in US, FTC may apply

⚠️ TFSA is a common trap — it is NOT treated as a pension plan under the treaty, so annual growth is fully taxable in the US.

🇩🇪 German Pension (Deutsche Rentenversicherung)

Treaty applicable?Yes — US-Germany Treaty 2006
State pensionResidence country only (treaty)
Private pension (Riester/Rürup)Complex — treaty may not cover all types
FBAR reportingRequired if >$10k
Form 8833Yes — for treaty position

German Riester pension may not qualify for treaty deferral — consult specialist.

🇫🇷 French Pension

Treaty applicable?Yes — US-France Treaty 1994
State pensionResidence country only (treaty)
Assurance VieComplex — may be PFIC or foreign trust
French CSG/CRDS as FTCPartially denied — Rev. Rul. 2008-19
FBAR reportingRequired if >$10k

🇨🇭 Swiss Pillar 2 / Pillar 3a

Treaty applicable?Yes — US-Switzerland Treaty 1996
Pillar 2 (occupational)Treaty protection — taxed at distribution
Pillar 3a (individual)May qualify for treaty deferral
FBAR reportingRequired if >$10k
Form 8833Yes — to claim treaty position

🇳🇿 KiwiSaver

Treaty protection?Unclear — debated
Annual earnings taxable in US?Likely yes — treated as foreign trust or PFIC
Form 3520May be required if foreign trust
FBAR reportingRequired if >$10k

KiwiSaver is a high-risk area for US-NZ dual citizens. Specialist advice strongly recommended.

🇸🇬 CPF (Central Provident Fund)

Treaty protection?Limited — US-Singapore Treaty 1981
CPF interest/growthLikely taxable annually in US
FBAR reportingRequired if >$10k
Form 8938If above FATCA thresholds

No IRS ruling on CPF. Most advisors report CPF interest as taxable in the US annually.

🇯🇵 Japanese iDeCo / Employees' Pension

Treaty applicable?Yes — US-Japan Treaty 2003
State pension (Kokumin Nenkin)Residence country only (treaty)
iDeCo (private DC)Complex — treaty may not cover
FBAR reportingRequired if >$10k

🇮🇳 Indian EPF / NPS

Treaty applicable?Limited — US-India Treaty 1989
EPF (Employee Provident Fund)Likely taxable in US — no clear treaty protection
NPS (National Pension)Growth may be taxable annually in US
FBAR reportingRequired if >$10k
No totalization agreementDual FICA possible

Pension Tax Analysis

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Key Reporting Forms

FBAR FinCEN Form 114

Required if total foreign financial accounts (including pension accounts) exceed $10,000 at any point. Filed online via BSA E-Filing. Deadline: April 15 (auto-extension to Oct 15). Penalty: up to $10k per violation ($100k+ if willful).

8938 FATCA Statement

Foreign financial assets including pensions if above threshold: single abroad $200k (year-end) or $300k (any time); MFJ $400k/$600k. Attach to Form 1040. Penalty: $10k for failure to disclose.

8833 Treaty Position Disclosure

Required when claiming a treaty benefit that overrides the default US tax treatment. Common for pension income. Penalty: $1,000 failure to disclose.

3520 Foreign Trust Reporting

Some foreign pensions (KiwiSaver, some Australian Super arrangements) may be classified as foreign trusts. Form 3520 and 3520-A may be required. Penalty: 35% of gross value for failure to file.

1116 Foreign Tax Credit

Claim a credit for foreign taxes paid on pension income. May reduce or eliminate US tax on the same income, depending on treaty and income baskets.

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