US·UK Accountants

Insights · Cross-Border Planning

Inheriting a US IRA or 401(k) While Living in the UK: What Actually Happens

Inherited a US retirement account as a UK resident? Here's how inherited IRAs and Roth IRAs are taxed across both countries, the 10-year rule, and the decisions worth making slowly.

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By Sam H., Founder & Lead Advisor

ACCA · ACA · Reviewed by Sal T. · 2026-08-25

Every month we speak to someone in the UK who has just inherited a US retirement account — an IRA, a Roth IRA, a 401(k) — from a parent or relative in America. The letters from the US custodian are confusing, the amounts are meaningful, and the instinct is almost always the same: get the money over here as quickly as possible.

It's an understandable instinct. It's also, in most cases, the most expensive one available.

The good news first

The inheritance itself is not taxed on either side of the Atlantic in the typical case. The UK has no tax on receiving an inheritance, and US estate tax is the estate's affair, not yours, and rarely applies below very high thresholds. So the money is yours. The question is not whether you keep it — it's how and when you take it out of its wrapper, because that is the moment tax happens.

Traditional and Roth accounts are different animals

An inherited traditional IRA or 401(k) is a bundle of income that has never been taxed. Every withdrawal is taxable income — in the US, and generally also in the UK once you're resident here, with the treaty and foreign tax credits deciding who collects what. Take it all in one year and you can push yourself into higher bands in both countries at once. Spread it thoughtfully and the same money can come out at a fraction of the cost.

An inherited Roth IRA is the opposite: the tax was paid long ago by the person who left it to you. Qualified withdrawals are tax-free in the US, and — claimed correctly — the treaty generally lets that treatment hold in the UK too. Which leads to a conclusion that surprises people: an inherited Roth is often the last money you should touch, because every year it stays invested is another year of genuinely tax-free growth.

The 10-year clock

For most deaths after 2019, US rules require the inherited account to be emptied by 31 December of the tenth year after the year of death. Living in the UK doesn't pause that clock — but ten years is a long runway, and the difference between a panicked year-one withdrawal and a planned schedule across the window is frequently measured in thousands of pounds.

What we'd tell you before you touch anything

Confirm the account type and its history. Establish the ten-year deadline from the actual date of death. Model the withdrawal schedule against your UK income bands and the US position together — not separately. And only then move money. The custodian's paperwork can wait a few weeks; a withdrawal cannot be undone.

If you've recently inherited a US retirement account, this is exactly the work we do — a written plan built on your figures, before anything irreversible happens.

Frequently asked questions

The inheritance itself is not taxed in the UK — Britain has no tax on receiving an inheritance. What the UK can tax is what happens next: withdrawals from the inherited account while you are UK resident are generally taxable here, with the US-UK treaty deciding how the two countries share the bill. The treatment differs sharply between traditional and Roth accounts, which is why the account type matters more than the amount.

Yes. For most people inheriting a US IRA from someone who died after 2019, the account must be fully distributed by 31 December of the tenth year after the year of death — your country of residence does not change that clock. What your UK residence changes is the tax cost of each withdrawal along the way, which is why the sequencing within those ten years is the real planning question.

Often largely yes, when handled correctly — qualified Roth distributions are tax-free in the US, and the treaty generally lets the UK respect that treatment. But the position depends on the account's history and how the claim is made on both returns, so it should be established for your facts rather than assumed.

Usually not immediately, and sometimes not at all until the deadline requires it. Money inside the account keeps growing tax-free; a rushed lump-sum withdrawal can create tax in one or both countries that patience would have avoided. The transfer of cash to the UK is the easy part — it is the withdrawal decision that deserves professional modelling first.

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