United Kingdom
US Tax CPA for Americans in the UK
The UK changed the rules for new arrivals on 6 April 2025. For a US citizen the interesting part is what it does to the American return — a year with little UK tax is a year with little foreign tax credit, and the bill can move from HMRC to the IRS.
We prepare the US side for Americans in Britain: the return, the elections, and the planning that decides which country ends up taxing what.
What changed in 2025 — and what it does to your US return
Non-domiciled status and the remittance basis ended on 6 April 2025. Your UK accountant handles the UK side. Our job is the part that lands on your 1040.
The change
What happened
A four-year regime for foreign income and gains replaced the remittance basis. Claim it and the UK stops taxing that income for a few years — at the cost of some UK allowances.
- Applies early in UK residence
- Claimed on the UK return
- Neither automatic nor free
On your 1040
Credits you lose
The IRS credits only tax you actually paid. A year with no UK tax on that income is a year with nothing to put on Form 1116 — and the income is still taxable in the United States.
- The income stays US-taxable
- No UK tax paid, no credit
- The saving moves to the IRS
On your 1040
Both directions
The same claim gives up UK allowances, which raises UK tax on your UK-source income — and that raises your credit. The two effects pull opposite ways. Which one wins is arithmetic on the American return.
- Less credit on foreign income
- More credit on UK income
- Your mix decides it
Before you claim
Four years is a decision, not a default
The claim is made on a UK return and its cost shows up on a US one. We run it both ways before your UK return is filed, because that is the moment the US consequence is locked in.
What we do for Americans in the UK
US filings, prepared with the UK position in front of us rather than after the fact.
Compliance
The annual return
Form 1040 with the schedules a UK life actually generates — Forms 2555, 1116, 8938 and FinCEN 114 — plus any state return you have not shaken off.
- Federal and state returns
- FBAR and FATCA reporting
- Extensions to October 15
Reliefs
Credit planning
Exclusion or credit is arithmetic, not preference — and a UK relief year changes the arithmetic.
- Exclusion up to $132,900 for 2026
- Foreign tax credit carryforwards
- The effect of a UK claim
Retirement
UK pensions
Employer schemes, SIPPs, transfers and lump sums, with the treaty positions taken deliberately and the reporting that goes with them.
- Contributions and growth
- Lump sums and drawdown
- Reporting on the US return
Investments
Funds and ISAs
A UK fund typically meets the test for a passive foreign investment company, and an ISA wrapper does not change that.
- PFIC testing on each holding
- Form 8621 and the elections
- Section 1291 exposure
Family
Estate exposure
UK inheritance tax moved to a residence test in 2025 while US estate tax still follows citizenship. A long stay in Britain can put you inside both.
- Where the two systems overlap
- Non-citizen spouse limits
- Estate and gift treaty relief
Late filers
Catching up
Streamlined Foreign Offshore takes three years of returns and six years of FBARs, with no offshore penalty where the failure was non-willful.
- The non-residency test
- Non-willful certification
- Penalty relief
How the work runs
Review
We read last year’s US return, your UK residence timeline and your account and pension statements, and tell you where the exposure sits.
Plan
Exclusion or credit, whether the UK relief helps or costs you, what to do about funds and pensions — settled before anything is filed.
File
We prepare and file the US returns and information reports, and coordinate with your UK accountant so both sides agree.
US expat tax in the UK — questions we get
Should I claim the four-year relief if I am a US citizen?
Not automatically, and the reason sits on the US side. The relief means little or no UK tax on that foreign income for a few years — but the United States taxes its citizens on worldwide income regardless. The foreign tax credit covers only the tax you actually paid, so a year with no UK tax on that income is a year with no credit to set against the US charge on it.
There is a second effect running the other way: the claim costs you UK allowances, so UK tax on your UK-source income goes up, and that produces more credit. Which effect dominates depends on your mix of income. Your UK accountant makes the claim — we tell you what it costs on the American return before they do.
Which side do you actually handle?
The US side, and only the US side. We are a US CPA practice: we prepare the 1040 and the international schedules that go with a UK life, run the elections and credit calculations, and handle the account and pension reporting. We do not prepare UK returns and we are not UK tax advisers.
What we do bring is the American consequence of your UK decisions, which is the part that usually goes unexamined. Where you have a UK accountant we coordinate with them so both returns tell the same story. More detail: our US expat tax guide, the US–UK tax treaty explained, our international tax services, and expat support in other countries.
Is my ISA tax-free for US purposes?
No. An ISA is a UK wrapper, and that shelter does not travel to a US return — the income and gains inside it are reportable in the United States.
It then works against you a second time: because no UK tax was paid on that income, there is no foreign tax credit to offset the American charge. And if the ISA holds UK funds, those raise a separate problem of their own.
Why are my UK funds a problem on a US return?
A foreign corporation is a passive foreign investment company if 75% or more of its gross income is passive, or at least 50% of its average assets produce passive income. A UK fund will typically meet one of those tests.
Without a qualified electing fund or mark-to-market election, distributions and gains fall into the section 1291 excess distribution rules, which throw the gain back over your holding period and add an interest charge. Each holding is reported separately on Form 8621 — so a portfolio assembled sensibly by a UK adviser can produce a long and expensive US filing.
How does the change to UK inheritance tax affect an American?
Broadly, UK inheritance tax now follows residence rather than domicile, and after a long enough stay it reaches worldwide assets. Exactly where you fall is a UK question for a UK adviser.
The American question is ours. US estate tax follows citizenship wherever you live, with a basic exclusion of $15,000,000 for 2026, and there is a US–UK estate and gift tax treaty that governs how the two systems meet. A long-stay American can sit inside both at once, which is worth mapping years before it matters.
My spouse is British and not a US citizen. Does that matter?
Yes, and it catches people out. The unlimited marital deduction that lets one US spouse leave everything to the other does not apply where the recipient spouse is not a US citizen. Lifetime gifts to such a spouse are limited to an annual exclusion of $194,000 for 2026, and transfers at death generally need a qualified domestic trust if the tax is to be deferred. This is worth planning years ahead.
I have not filed US returns since moving. What are my options?
The Streamlined Foreign Offshore Procedures exist for exactly this. They require three years of returns, six years of FBARs, and a certification that the failure was non-willful — due to negligence, inadvertence, mistake, or a good faith misunderstanding of the law — along with physical presence outside the United States for at least 330 full days in one of the relevant years.
Where the requirements are met, the IRS states the taxpayer will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties. Most people who simply did not know are eligible — worth checking before the choice is made for you.
Book a call
Schedule a call
Thirty minutes, no charge. Bring your UK arrival date and last year’s returns, and we will tell you what you are required to file, whether the UK relief helps you or costs you, and what the exposure is if you are behind.