British Expats - Are UK sipp pensions really exempt from PFIC reporting

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Originally Posted by atrgo38521 (Post 13329077)

Reading all the relevant and very useful posts, this all leads me to believe that I can convert my current contract-based workplace pension I have with Standard Life (GFRP to be precise) to an International SIPP, and assuming no further contributions to that SIPP I am not going to be subject to 3520 / 3520-A reporting to the IRS going forward. My Standard Life pension was a defined-contribution type and viewed as an 'employment trust', with 100% contribution made by my former employer in the UK. Thanks

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Originally Posted by Glasgow Girl (Post 13327978)

First, generally agree with everything jlaws states. Good information provided, Some additional clarification on your response,

(2) A SIPP is indeed a Foreign Grantor Trust. Rev. Proc 2020-17, issued by the IRS pretty much clarified that Form 3520 is not required so long as it is reported as appropriate on an FBAR and Form 8938.

Correct. Make sure you report the existing DC plan on an FBAR and Form 8938 as applicable, and then the SIPP when the conversion is made. The IRS will never state unequivocally that Form 3520 is not required for a SIPP but per the above most professionals will agree that Rev. Proc 2020-17 makes that all but fact.