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US citizens in the UK · Institutions

Which Embark Pensions (formerly Hornbuckle) accounts accept US citizens

Last checked

Embark Pensions (formerly Hornbuckle) offers a pension to a US person, with strings.

If you already have an account with Embark Pensions (formerly Hornbuckle), a second one there is usually the easier application, because Embark Pensions (formerly Hornbuckle) has already checked who you are. Each account below carries its verdict, the evidence behind it and the date it was checked.

At a glance

Account Verdict Last checked
SIPPs With strings

SIPPs

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With strings

US persons: UK residents only, and only through a regulated adviser

The Hornbuckle brand no longer writes new business and the live product is the Embark Pensions Full SIPP. It publishes no bar on US citizens, and its assessment says the SIPP is available only to customers resident in the United Kingdom and only where the customer has taken advice from a regulated adviser. So you meet the residence test and cannot apply alone.

FSCS £85,000 investment cover · adviser introduced · UK residents only

Account Terms The catch
Full SIPP
Annual fee
£420 a year plus VAT, with nothing to set up
Dealing fee
£25 plus VAT a year for each standard investment after the first; dealing is charged by your broker
Can hold
Standard investments held directly or through a manager, platform or broker, plus commercial property.
Individual shares
Yes
 UK residents only and adviser introduced. Transfers in cost £50 a scheme.

Source: Embark Pensions Full SIPP fair value assessment and fee schedule, 2026-08-17 Last checked Embark Pensions (formerly Hornbuckle)'s own page

Account names link to the provider's own site. momo has no active affiliate partnerships; if that changes it will be disclosed and will never change a verdict. Every institution, A to Z.

Confirm your own position with a cross-border specialist. Acceptance policies and tax rules change, and your facts may differ from the general case. Rates and terms here are the provider's published figures rather than an offer, and the provider decides each application on its own criteria. Use this as a map, not a ruling. Last checked .
Tax

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 Tax

US-UK tax treaty

The US-UK treaty stops most double taxation, but the saving clause lets the US tax its citizens almost as if it were not there. What survives the clause.

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Form 3520

A UK pension held in trust can be a foreign trust to the IRS. Rev. Proc. 2020-17 exempts qualifying retirement trusts from Forms 3520 and 3520-A, on conditions.