UK funds after moving to the US are not a reason to sell first and investigate later. The costly mistake is treating a platform's request, an ISA wrapper or a fund's familiar UK name as a US tax classification. Before you sell, transfer or close anything, build the record that lets a qualified preparer identify each investment and test the filing questions.
This checklist is for a US citizen or other US taxpayer moving from the UK to the United States, or another country, with UK pooled investments. It covers the record-and-reporting decisions around unit trusts, OEICs, ETFs and similar holdings. It does not say that every UK fund is a passive foreign investment company (PFIC), that every holder must file Form 8621, or that keeping or selling an investment is right for you.
1. Capture the UK fund records before access changes
Start with the investments, not the account label. A stocks and shares ISA, general investment account, workplace arrangement and nominee platform can each contain different issuers. Your preparer needs enough detail to identify the actual asset, not just a monthly balance or a screenshot saying “funds”.
Download the documents while the UK provider still permits access. Keep:
- the provider and account number, account type and account currency;
- each fund's legal name, ISIN or other identifier, domicile and share class where shown;
- acquisition dates, trade confirmations, units, cost records and corporate-action notices;
- annual tax vouchers, income and distribution statements, and any tax deducted;
- year-end valuations and the highest account values during the US calendar year; and
- any prior US Form 8621, Form 8938 or FBAR filings.
Use the free US PFIC record checker once you have that file. It is useful for turning account statements into a holding-by-holding questions list: issuer, domicile, purchase date, distribution history and previous elections. It cannot classify a fund, decide whether a form is required, calculate tax or recommend a sale.
2. Treat PFIC status as an issuer question, not a UK-label question
The IRS instructions say a foreign corporation is a PFIC if it meets an income or asset test. The same instructions set out circumstances in which a US person who is a direct or indirect shareholder may need to file Form 8621. Those are technical tests based on the entity and the holder's facts; a UK platform or fund description is not a substitute for that analysis.
Do not assume that every non-US fund is a PFIC, but do not assume the opposite because the holding sits inside an ISA or pays a modest distribution. Give the preparer the complete fund record and ask what information is still needed. If the adviser asks for an annual information statement, historic distributions or a particular election analysis, request that from the provider before its service deadline.
For example, Maya returns from Manchester with two UK funds inside an ISA and one in a general account. Rather than instructing an immediate sale, Maya records the three issuers, all purchase dates and every account's maximum balance, then asks a US international-tax preparer to review the holdings alongside the planned provider action. That preserves choices and makes the tax question answerable.
3. Check the account reports separately from the fund analysis
Fund classification does not replace foreign-account reporting. FinCEN says that a US person with a financial interest in, or signature authority over, foreign financial accounts generally must file an FBAR when the aggregate maximum value exceeds $10,000 at any point in the calendar year. The test is based on the calendar-year maximums across the relevant accounts, not on a closing balance after you land in the United States.
Start with the FBAR and FATCA filing checker once every non-US account is listed. Enter the ownership, currency and maximum balance evidence. The tool helps organise the aggregate-account test and the Form 8938 question; it does not decide whether a pension, trust, fund or company is reportable, and it does not submit an FBAR or tax return.
Form 8938 is a separate IRS reporting test for specified foreign financial assets. IRS guidance includes foreign financial accounts and, in some cases, foreign stock, entity interests and investments held outside an account. It also explains that an asset reported on Form 8621 can still need to be counted when testing the applicable Form 8938 threshold, even where the Form 8938 entry itself is handled through Part IV. Give one preparer the full account-and-asset inventory rather than trying to solve each form in isolation.
4. Keep the UK and US tax records on the same timeline
The UK tax year and the US calendar year do not use the same dates. A distribution, sale, tax voucher or provider restriction close to your move can therefore belong in different parts of the two records. Record the event date, settlement date, amount, currency, UK tax evidence and the US dollar conversion method used by your preparer.
The US tax calendar helps place provider deadlines, return preparation and information-reporting tasks in one sequence. It is an organiser, not an extension, a filing service or a determination of the form due. If the move year includes a sizeable portfolio, a US state return, UK tax paid or several years of planned changes, the premium multi-year move planner can prepare an adviser-ready timeline of assumptions. It does not calculate a final US or UK tax result or select investments.
Do not treat a UK tax voucher as proof of a US credit or assume that UK tax automatically removes the US question. The IRS foreign-tax-credit guidance distinguishes the tax paid or accrued from the credit calculation and may require Form 1116. A cross-border adviser can coordinate the income type, dates, UK tax evidence and any separate residence-year issues before you make a material trade.
When professional advice should come before a transaction
Arrange US international-tax advice before a material sale, transfer or provider-driven closure if you hold pooled UK funds, have prior Form 8621 filings or elections, own investments through a company or trust, have a large portfolio or may be resident in two countries in the move year. Also get advice if you have unfiled US returns or FBARs, a UK property or pension transaction, employee equity, a US state residence question or a request to make a tax election without a complete holding history.
Guidance, not advice: ExpatCompass tools help organise account, date and scenario records. They do not classify an investment, determine a filing obligation, calculate tax or replace US or UK professional advice.
A practical UK funds-to-US order
- List every UK account and every investment inside it before you give a provider a transfer or closure instruction.
- Download identifiers, purchase records, statements, distributions, tax vouchers and maximum-balance evidence.
- Use the PFIC record checker to identify the questions a preparer must answer for each issuer.
- Run the FBAR account inventory for the whole US calendar year and test Form 8938 separately.
- Put UK and US event dates, tax evidence and provider deadlines on one timeline.
- Obtain written cross-border advice before a material trade, election, transfer or closure, then retain it with the return file.
The useful result is not a rushed investment decision. It is a complete, time-stamped file that gives you and your preparer room to make a deliberate reporting and investment decision.