UK resident, US and U.K. taxpayer, ETF investing

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USUKTax
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UK resident, US and U.K. taxpayer, ETF investing

Post by USUKTax » Wed Jun 19, 2019 10:30 am

I’m sorry, I don’t know if this is a US or U.K. forum question so I’ve gone with the US.

I’m a U.K. resident who holds U.K. and US citizenship. I therefore pay U.K. tax by virtue of living in the U.K. and a US taxpayer by virtue of being a US citizen.

I understand the standard US Vanguard funds are not compliant with U.K. tax law and any gains would be taxed as income. I also understand there are PFIC issues with U.K. ETFs. What U.K. ETFs are available to me that can replicate a three-fund portfolio without adverse tax consequences?

Many thanks

Valuethinker
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by Valuethinker » Wed Jun 19, 2019 10:47 am

USUKTax wrote:
Wed Jun 19, 2019 10:30 am
I’m sorry, I don’t know if this is a US or U.K. forum question so I’ve gone with the US.

I’m a U.K. resident who holds U.K. and US citizenship. I therefore pay U.K. tax by virtue of living in the U.K. and a US taxpayer by virtue of being a US citizen.

I understand the standard US Vanguard funds are not compliant with U.K. tax law and any gains would be taxed as income. I also understand there are PFIC issues with U.K. ETFs. What U.K. ETFs are available to me that can replicate a three-fund portfolio without adverse tax consequences?

Many thanks
I would check all of Ted Swipett's posts on this forum. UK citizen who lived in America.

However that may not cover your situation.

AFAIK there are no UK or European listed ETFs that meet your needs, i.e. escape PFIC.

There *are* a list of US funds, that HMRC has, that are "Reporting" and so are OK from a UK tax point of view. You'll have to dig that out and check it out, fund by fund.

Then you have to find a broker who will let you buy US listed ETFs or Funds. My understanding is that post EU PRIP (? acronym) that's extremely difficult, if not impossible -- because the funds don't conform to EU risk documentation requirements, you can't invest in them (you may be able to get clearance as what was once called an ?intermediate? investor, i.e. you have more than certain assets and you have made these kinds of investments before). You might be able to do it through Jersey, etc. If you happen to have a US broking account, that's a way to do it.

If none of this works then you can try to synthesize by directly holding a portfolio of shares which is a lot of work and hassle.

But I don't know of any other way that a US person based in Europe gets around it. Either find a broker who deals in US ETFs, or don't invest.

Valuethinker
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by Valuethinker » Wed Jun 19, 2019 11:10 am

BTW you might get a better response if you asked on the non US investing sub forum, here.

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USUKTax
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by USUKTax » Wed Jun 19, 2019 11:16 am

Thank you for the very comprehensive response. I invest through Interactive Brokers, but they don’t appear to allow me to invest in US funds (I assume for the reasons you outline above). I’m doubly hurt because my employer won’t allow me to buy single stocks, so I feel like I’m being restricted on all counts!

Your tip regarding which forum to use is also much appreciated. I’ll do that now.

Valuethinker
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by Valuethinker » Wed Jun 19, 2019 11:47 am

USUKTax wrote:
Wed Jun 19, 2019 11:16 am
Thank you for the very comprehensive response. I invest through Interactive Brokers, but they don’t appear to allow me to invest in US funds (I assume for the reasons you outline above). I’m doubly hurt because my employer won’t allow me to buy single stocks, so I feel like I’m being restricted on all counts!

Your tip regarding which forum to use is also much appreciated. I’ll do that now.
Then it is possible you are well and truly (done) from an investing/ tax point of view.

As in no way to possibly invest in a tax efficient manner - or in a manner which is not punitive vis a vis US tax.

You won't be the only person in this situation, and it's worth surfing around various internet forums to see if anyone has found a way around this problem (PRIP implementation is relatively new so people are perhaps only discovering it).

Solutions include relinquishing US citizenship (that's not easy).

If you PM me I can give you the name of a (not cheap) London accountant who seems to know something about this stuff, but you may be able to find someone else.

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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by TedSwippet » Wed Jun 19, 2019 4:03 pm

Welcome.
USUKTax wrote:
Wed Jun 19, 2019 11:16 am
Thank you for the very comprehensive response. I invest through Interactive Brokers, but they don’t appear to allow me to invest in US funds (I assume for the reasons you outline above). I’m doubly hurt because my employer won’t allow me to buy single stocks, so I feel like I’m being restricted on all counts!
It appears that you've got correct responses so far. And it certainly looks like you may well be stuffed as far as investing is concerned.

Most Vanguard US domiciled ETFs are on HMRC's 'reporting funds' list, so if you can access them then you will avoid both US PFIC issues and the UK's non-reporting funds issue. Unfortunately for you, as of the start of 2018, an EU regulation known as PRIIPs has effectively made these unavailable to EU residents. However, if you were to buy any non-US domiciled funds or ETFs, the US's appalling PFIC tax regime could eat you alive.

Can you find a US based broker that will take you as a client? Perhaps Schwab International, if you plead hard enough? They may have no problem offering US domiciled ETFs to anybody, because they are not bound by EU regulations. If you have a US address you can use, that might help. As a US citizen, you will find it hard to impossible to open accounts with many UK based brokers, thanks to another horrible US tax law known as FATCA.

As for not being able to buy individual stocks ... is this inside an employer pension or plan of some kind or another, or a blanket ban because you work in financial services in some capacity? If the former, you could be a bit less stuffed than otherwise, because the US's PFIC nonsense does not reach into any UK pension plan you might hold. Not so with an ISA of course -- the US entirely fails to acknowledge the ISA wrapper there, so these are as toxic to you as a taxable account would be.

If it's a blanket ban due to your job, then you are mostly out of options. Your only remaining route I can see is to bite the bullet and swallow the least worst PFIC tax treatment, mark-to-market. You might lose considerably through having to pay US income tax rates annually on capital gains (although sometimes using foreign tax credits can save you from the worst of that), the US paperwork is horrific, and the interaction between this and UK capital gains tax could be awful, but there appear to be no other choices, short of simply not investing at all.

I'm sorry that you are stuck with this problem. With each passing day I am ever more grateful that I did not take out US citizenship when I had the opportunity.
Last edited by TedSwippet on Wed Jun 19, 2019 4:13 pm, edited 2 times in total.

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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by oldcomputerguy » Wed Jun 19, 2019 4:12 pm

This topic is now in the Non-US Investing forum.

USUKTax, since you're asking in particular about UK ETFs, hopefully you'll get more helpful replies here.
It’s taken me a lot of years, but I’ve come around to this: If you’re dumb, surround yourself with smart people. And if you’re smart, surround yourself with smart people who disagree with you.

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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by Valuethinker » Thu Jun 20, 2019 3:09 am

TedSwippet wrote:
Wed Jun 19, 2019 4:03 pm
Welcome.
USUKTax wrote:
Wed Jun 19, 2019 11:16 am
Thank you for the very comprehensive response. I invest through Interactive Brokers, but they don’t appear to allow me to invest in US funds (I assume for the reasons you outline above). I’m doubly hurt because my employer won’t allow me to buy single stocks, so I feel like I’m being restricted on all counts!
It appears that you've got correct responses so far. And it certainly looks like you may well be stuffed as far as investing is concerned.

Most Vanguard US domiciled ETFs are on HMRC's 'reporting funds' list, so if you can access them then you will avoid both US PFIC issues and the UK's non-reporting funds issue. Unfortunately for you, as of the start of 2018, an EU regulation known as PRIIPs has effectively made these unavailable to EU residents. However, if you were to buy any non-US domiciled funds or ETFs, the US's appalling PFIC tax regime could eat you alive.

Can you find a US based broker that will take you as a client? Perhaps Schwab International, if you plead hard enough? They may have no problem offering US domiciled ETFs to anybody, because they are not bound by EU regulations. If you have a US address you can use, that might help. As a US citizen, you will find it hard to impossible to open accounts with many UK based brokers, thanks to another horrible US tax law known as FATCA.

As for not being able to buy individual stocks ... is this inside an employer pension or plan of some kind or another, or a blanket ban because you work in financial services in some capacity? If the former, you could be a bit less stuffed than otherwise, because the US's PFIC nonsense does not reach into any UK pension plan you might hold. Not so with an ISA of course -- the US entirely fails to acknowledge the ISA wrapper there, so these are as toxic to you as a taxable account would be.

If it's a blanket ban due to your job, then you are mostly out of options. Your only remaining route I can see is to bite the bullet and swallow the least worst PFIC tax treatment, mark-to-market. You might lose considerably through having to pay US income tax rates annually on capital gains (although sometimes using foreign tax credits can save you from the worst of that), the US paperwork is horrific, and the interaction between this and UK capital gains tax could be awful, but there appear to be no other choices, short of simply not investing at all.

I'm sorry that you are stuck with this problem. With each passing day I am ever more grateful that I did not take out US citizenship when I had the opportunity.
The only other thing I can think of is a broker outside of EU financial services legislation.

That might be Switzerland (but they have treaties). It might be Guernsey Jersey Isle of Man (doubt it, but not sure). Or it might be British Virgin Islands, Grand Cayman, Panama. As long as OP can convince them he's not trying to launder money nor escape FATCA... Mauritius might be another possibility. UAE.

If UK pensions work for US taxes, that's a big win. £1m lifetime limit is a hard constraint, but at least one can build up to that by basically contributing (if company allows salary surrender, so National Insurance 13.8% on top) one's entire income down to the Basic Personal Allowance.

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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by TedSwippet » Thu Jun 20, 2019 3:37 am

Valuethinker wrote:
Thu Jun 20, 2019 3:09 am
The only other thing I can think of is a broker outside of EU financial services legislation. That might be Switzerland (but they have treaties). It might be Guernsey Jersey Isle of Man (doubt it, but not sure). Or it might be British Virgin Islands, Grand Cayman, Panama. As long as OP can convince them he's not trying to launder money nor escape FATCA... Mauritius might be another possibility. UAE.
Might be possible, but likely to be tricky. I cannot think of any brokers located in these places that I would want to trust, and FATCA has practically every non-US financial institution leery of US citizen customers to the point where many will just not accept US citizens as customers any longer. If nothing else, US citizen customers can represent a large and uncompensated paperwork and compliance burden.

A dual citizen can of course hide their US citizenship much more easily than somebody who is only a US citizen, and in fact quite a few now do just that in order simply to survive financially outside the US, but it's a risky move where significant funds are involved.
Valuethinker wrote:
Thu Jun 20, 2019 3:09 am
If UK pensions work for US taxes, that's a big win. £1m lifetime limit is a hard constraint, but at least one can build up to that by basically contributing (if company allows salary surrender, so National Insurance 13.8% on top) one's entire income down to the Basic Personal Allowance.
Pensions are covered by the US/UK tax treaty, and are (for once) not negated by the US's spiteful treaty 'saving clause' (treaty article 1 para 4). However, contributions are limited to the maximum that would be allowed in a comparable US pension scheme, so a 401k (treaty article 18 para 2). And 401ks have contribution limits that are generally lower than UK ones, including the nasty (because it's usually only determinable retrospectively, and so hits retroactively) 'highly compensated employee' (HCE) limitation.

There is also considerable argument among professionals over which types of UK pension meet the treaty definition. An employer one could, being 401k-like, but a SIPP might not. Or might. Nobody really knows.

It all makes you very grateful not to be a US citizen, doesn't it?

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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by ivk5 » Thu Jun 20, 2019 5:08 am

I’m also a dual US/EU citizen, though currently residing in neither. I opened US accts while living in US, and have had no difficulty continuing to invest as a non-resident. Additionally I’ve been able to open new bank accts while a non-resident. In both cases I continued using US address as a non-resident - either of a family member or of my (past and present) employer. I have not tried to open a brokerage acct while a non-resident.

I would second the suggestions to try to open a US brokerage acct. As mentioned Schwab Intl is considered expat friendly though I have no first-hand experience.

typical.investor
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by typical.investor » Thu Jun 20, 2019 5:34 am

TedSwippet wrote:
Wed Jun 19, 2019 4:03 pm
Perhaps Schwab International, if you plead hard enough? They may have no problem offering US domiciled ETFs to anybody, because they are not bound by EU regulations. If you have a US address you can use, that might help. As a US citizen, you will find it hard to impossible to open accounts with many UK based brokers, thanks to another horrible US tax law.
Open a Schwab International account via Schwab UK.

https://www.schwab.co.uk/public/schwab- ... -investing
It only takes about 10 minutes. Let's get started.

Each applicant will need:
A minimum of US $25,000 is required to open an international brokerage account.
Non-U.S. Residence Address
Digital copy of passport or government ID
Tax Identification Number or Social Security Number (for U.S. citizens living abroad)
Employer’s name and mailing address (if applicable)
Digital copy of most recent utility bill
Printer and scanner to print, sign and upload required documents
Ted's right. It's actually a US account under US law. You can get the US Vanguard Funds that are UK compliant that way.
In opening this U.S. Dollar Brokerage Account, you understand that the account you hold with Charles Schwab, U.K., Limited ("Schwab UK") will be a US Dollar brokerage account. Schwab UK will clear orders through its affiliate, Charles Schwab & Co., Inc. ("Schwab"). Schwab UK categorises all clients as "Retail clients" other than where advised. In establishing a U.S. brokerage account (either individual or corporate), Schwab U.K. will introduce you to Schwab a U.S. broker-dealer, and the account will be operated by Schwab from the U.S. Schwab is regulated under U.S. securities laws and is not authorised in the U.K. All or most of the protections provided by the U.K. regulatory system do not apply but U.S. securities protections do.

Valuethinker
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by Valuethinker » Thu Jun 20, 2019 5:43 am

typical.investor wrote:
Thu Jun 20, 2019 5:34 am
TedSwippet wrote:
Wed Jun 19, 2019 4:03 pm
Perhaps Schwab International, if you plead hard enough? They may have no problem offering US domiciled ETFs to anybody, because they are not bound by EU regulations. If you have a US address you can use, that might help. As a US citizen, you will find it hard to impossible to open accounts with many UK based brokers, thanks to another horrible US tax law.
Open a Schwab International account via Schwab UK.

https://www.schwab.co.uk/public/schwab- ... -investing
It only takes about 10 minutes. Let's get started.

Each applicant will need:
A minimum of US $25,000 is required to open an international brokerage account.
Non-U.S. Residence Address
Digital copy of passport or government ID
Tax Identification Number or Social Security Number (for U.S. citizens living abroad)
Employer’s name and mailing address (if applicable)
Digital copy of most recent utility bill
Printer and scanner to print, sign and upload required documents
Ted's right. It's actually a US account under US law. You can get the US Vanguard Funds that are UK compliant that way.
In opening this U.S. Dollar Brokerage Account, you understand that the account you hold with Charles Schwab, U.K., Limited ("Schwab UK") will be a US Dollar brokerage account. Schwab UK will clear orders through its affiliate, Charles Schwab & Co., Inc. ("Schwab"). Schwab UK categorises all clients as "Retail clients" other than where advised. In establishing a U.S. brokerage account (either individual or corporate), Schwab U.K. will introduce you to Schwab a U.S. broker-dealer, and the account will be operated by Schwab from the U.S. Schwab is regulated under U.S. securities laws and is not authorised in the U.K. All or most of the protections provided by the U.K. regulatory system do not apply but U.S. securities protections do.
Presumably you then have to pass their checks? So it could fall, later, on FATCA.

Fingers crossed. It seems to be the only way out of a serious jam for the OP (and others in his/her position).

typical.investor
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by typical.investor » Thu Jun 20, 2019 5:52 am

Valuethinker wrote:
Thu Jun 20, 2019 5:43 am
typical.investor wrote:
Thu Jun 20, 2019 5:34 am
TedSwippet wrote:
Wed Jun 19, 2019 4:03 pm
Perhaps Schwab International, if you plead hard enough? They may have no problem offering US domiciled ETFs to anybody, because they are not bound by EU regulations. If you have a US address you can use, that might help. As a US citizen, you will find it hard to impossible to open accounts with many UK based brokers, thanks to another horrible US tax law.
Open a Schwab International account via Schwab UK.

https://www.schwab.co.uk/public/schwab- ... -investing
It only takes about 10 minutes. Let's get started.

Each applicant will need:
A minimum of US $25,000 is required to open an international brokerage account.
Non-U.S. Residence Address
Digital copy of passport or government ID
Tax Identification Number or Social Security Number (for U.S. citizens living abroad)
Employer’s name and mailing address (if applicable)
Digital copy of most recent utility bill
Printer and scanner to print, sign and upload required documents
Ted's right. It's actually a US account under US law. You can get the US Vanguard Funds that are UK compliant that way.
In opening this U.S. Dollar Brokerage Account, you understand that the account you hold with Charles Schwab, U.K., Limited ("Schwab UK") will be a US Dollar brokerage account. Schwab UK will clear orders through its affiliate, Charles Schwab & Co., Inc. ("Schwab"). Schwab UK categorises all clients as "Retail clients" other than where advised. In establishing a U.S. brokerage account (either individual or corporate), Schwab U.K. will introduce you to Schwab a U.S. broker-dealer, and the account will be operated by Schwab from the U.S. Schwab is regulated under U.S. securities laws and is not authorised in the U.K. All or most of the protections provided by the U.K. regulatory system do not apply but U.S. securities protections do.
Presumably you then have to pass their checks? So it could fall, later, on FATCA.

Fingers crossed. It seems to be the only way out of a serious jam for the OP (and others in his/her position).
FACTA won't be an issue.

If the country of residence permits Schwab to open an account for their residents, Schwab will do so (via the Schwab International Account). Some countries do not permit their residents to do so, and thus Schwab won't.

There is no telling if the UK will change its rules though, so it best to do so now.

Topic Author
USUKTax
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by USUKTax » Thu Jun 20, 2019 1:58 pm

Thanks to everyone above who’s offered their help and expertise, there’s some great comments that I hope will be helpful to people who aren’t me.

Sadly my erstwhile employer requires me to use Interactive Brokers. From conducting more internet research I understand Interactive Brokers allow me to declare myself as a Professional (rather than a Retail) investor, which will allow me to access non-EU funds. There are some restrictions that I’ll also need to work through.

I’m also investigating whether my correspondence address could be moved to that of a US relative.

DouroBound
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by DouroBound » Wed Jul 10, 2019 12:11 pm

USUKTax wrote:
Thu Jun 20, 2019 1:58 pm
Thanks to everyone above who’s offered their help and expertise, there’s some great comments that I hope will be helpful to people who aren’t me.

Sadly my erstwhile employer requires me to use Interactive Brokers. From conducting more internet research I understand Interactive Brokers allow me to declare myself as a Professional (rather than a Retail) investor, which will allow me to access non-EU funds. There are some restrictions that I’ll also need to work through.

I’m also investigating whether my correspondence address could be moved to that of a US relative.
Thanks for this thread USUKTax. My wife and I are in the same boat (or rather, we are about to be). This thread and others have been really useful. Two questions for you: Have you managed to secure "Professional" status at IB (and if so has that solved your problem)? Did you have any luck pursuing the US address option? I just posted a question pretty similar to yours (viewtopic.php?f=22&t=285330), but I am looking for alternatives in case there is no way out of the PFIC/PRIIP/work-restriction trap. Have you looked into alternatives in case you are barred from buying equity? Real estate? Something else?

bgreat
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by bgreat » Wed Jul 10, 2019 12:18 pm

Valuethinker wrote:
Thu Jun 20, 2019 3:09 am
The only other thing I can think of is a broker outside of EU financial services legislation.

That might be Switzerland (but they have treaties). It might be Guernsey Jersey Isle of Man (doubt it, but not sure). Or it might be British Virgin Islands, Grand Cayman, Panama. As long as OP can convince them he's not trying to launder money nor escape FATCA... Mauritius might be another possibility. UAE.
Switzerland would in theory be OK: their treaties don't cover PRIIPS (Swiss Residents can hence buy US ETF's even from EU brokers). They are introducing their own version of PRIIPS next year, but it's much more relaxed (shouldn't block ETF purchases for example). The real issue is that Swiss brokers simply don't want US customers, and will require you to certify that you're not american when opening an account.

typical.investor
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by typical.investor » Wed Jul 10, 2019 9:01 pm

Again, try Schwab UK.

The account is operated under US laws (SIPC etc) and I believe offers access to US domiciled funds which means you can avoid PFIC rules.

Some Vanguard ETFs are UK reporting, and cost $4.95 to trade. Sorry, no mutual funds per regulation for non-US investors.

bgreat
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by bgreat » Thu Jul 11, 2019 11:28 am

typical.investor wrote:
Wed Jul 10, 2019 9:01 pm
Again, try Schwab UK.

The account is operated under US laws (SIPC etc) and I believe offers access to US domiciled funds which means you can avoid PFIC rules.

Some Vanguard ETFs are UK reporting, and cost $4.95 to trade. Sorry, no mutual funds per regulation for non-US investors.
This will get confusing fast...:

New UK customers are actually directed to Schwab US. Schwab UK also exists, but only residents of a limited number of countries are served by Schwab UK (more on that later). Both offer the same Schwab One International.

Schwab US have been reported to sell US-dom ETF's to their EU based customers. This might be perfectly legal, since Schwab US has nothing to do with the UK. I have seen no reports about Schwab UK, so it's unclear whether they sell US-dom funds to EU resident customers - I imagine they wouldn't due to EU laws, but in absence of evidence this is just speculation

There's a bit more information on the Schwab US/UK structure on the following Schwab page: apparently Schwab UK used to serve UK and Swiss customers, but they were all moved over to Schwab US around Brexit-preparation time. Schwab UK was serving Austria, France, Ireland, Italy, the Netherlands, and Sweden - but they're trying to find a new EU-based solution for those people:
https://www.schwab.co.uk/public/schwab- ... rexit.html

(New customer signups from the UK are being directed to Schwab US in any case. Post Brexit the EU regs likely won't apply, but that's all up in the air right now.)


Now Brexit is really the big factor in things here: post Brexit, it's likely that PRIIPS won't apply to UK customers after Brexit. So it's likely you'd be able to open a bog-standard IB account and trade US ETF's without any restrictions, whenever Brexit actually happens. (The only similar place I'm currently familiar with is Switzerland, and IB UK allows Swiss customers to trade US ETF's - so IB are aware and they do in fact only implement the restrictions for EU residents.) You might be able to even pick an arbitrary EU broker, because for non-EU customers they have no PRIIPS restrictions - but IB are likely still the best option (some EU brokers are too lazy to support US-dom ETF's just for their small number of non-EU customers).

And IB has the huge advantage of having by far the cheapest currency conversion (on the market, 2 USD commission). Schwab meanwhile don't publish their currency conversion rates, for my currency they charge 0.5%, and I can't see GBP:USD being much different.

TedSwippet
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Re: UK resident, US and U.K. taxpayer, ETF investing

Post by TedSwippet » Thu Jul 11, 2019 1:55 pm

bgreat wrote:
Thu Jul 11, 2019 11:28 am
Now Brexit is really the big factor in things here: post Brexit, it's likely that PRIIPS won't apply to UK customers after Brexit. So it's likely you'd be able to open a bog-standard IB account and trade US ETF's without any restrictions, whenever Brexit actually happens.
I am fairly sure that won't be the case, and that PRIIPs will continue to apply in the UK even after Brexit (sigh), at least for the foreseeable future. From this article (emphasis is mine):
PRIIPs Regulations Made in Preparation for Brexit
Friday, March 8, 2019
On February 28, the Packaged Retail and Insurance-based Investment Products (PRIIPs) (Amendment) (EU Exit) Regulations 2019 (UK Regulations) were published together with a draft explanatory memorandum.

The UK Regulations were laid before Parliament on January 9, as reported in the January 11 edition of Corporate & Financial Weekly Digest. There do not appear to be any substantive changes.

The purpose of the UK Regulations, which were made on February 27, is to ensure that the regime established under the Regulation on Key Information Documents for PRIIPs (PRIIPs Regulation) continues to operate effectively after the United Kingdom’s withdrawal from the European Union (Brexit).

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