Disclosing US income to HMRC is the half of catching up that nobody warns you about. An American in Britain who has fallen behind usually discovers the problem from the American end. The Streamlined routes are well documented, widely discussed, and the subject of a small industry.
The British half of the same problem gets almost no attention, and the same households tend to have it. A US brokerage account that never reached a Self Assessment return is as much HMRC's business as the IRS's.
HMRC's route back is the Worldwide Disclosure Facility, and it is the mechanism for disclosing US income to HMRC after the event. It runs on a 90-day clock, it expects you to calculate your own penalty, and it wants the money on the day you submit.
None of that is unreasonable, and none of it resembles the American process. People who have already been through a Streamlined filing arrive expecting something similar and meet a different animal entirely.
So this guide sets out what the facility covers, how the clock works, what you have to calculate yourself, and how to run it alongside an American catch-up without the two contradicting each other.
What is the route for disclosing US income to HMRC?
HMRC's route for putting right UK tax that went unpaid on something held or arising abroad. GOV.UK sets out the process, from the first notification through to the payment. It is a procedure rather than an amnesty, and it applies to individuals and companies alike.
Who can use it?
Anybody with an offshore element to a UK liability. The guidance opens it to anyone with UK tax to disclose where an offshore element is involved, and names individuals, companies and agents acting for others.
Onshore issues go in the same disclosure where they exist.
HMRC can refuse an application where assets appear to be criminal property.
So the facility is broad, and it is not a route for everybody in every circumstance.
In practice most people who come to us are nowhere near the refusal territory. They have a US account, a British return that never mentioned it, and a growing sense that time is not helping.
What counts as an offshore issue?
Income, gains or assets outside the United Kingdom that should have reached a UK return. For an American in Britain that usually means US investment income, an American rental property, or gains on US shares.
A US salary taxed through an American employer counts too, where UK tax should have applied.
The common thread is a British liability with a foreign source.
So the question is not where the account is, but which return the income should have reached.
Our UK Self Assessment service handles the years going forward once a disclosure closes the past, which is the half people forget to plan for.
| Stage | What happens | Timing |
|---|---|---|
| Notify | Tell HMRC through the Digital Disclosure Service | Before you start calculating |
| Acknowledgement | HMRC issues a disclosure reference number | Shortly after notifying |
| Disclose | Submit the figures, the tax and your own penalty calculation | Within 90 days of the acknowledgement |
| Pay | Full payment of the disclosed amount | On the day you submit |
How does the 90-day clock work?
It starts once HMRC acknowledges your notification. The guidance gives you 90 days from that point to gather the information, work out the liabilities and complete the disclosure using the reference number HMRC issues.
Notifying therefore starts a clock you cannot pause.
That is a reason to do the groundwork before notifying rather than after.
So assemble what you can, then notify, then finish.
Also note what the clock does not cover. Agreeing figures with a US adviser, waiting on a broker, or chasing an old employer all happen inside those 90 days rather than before them.
Can you get more time?
Yes, in complex cases. The guidance allows a request for up to 90 further days, which gives 180 in total, by contacting the offshore disclosure team directly. Nothing about the request is automatic, and HMRC decides whether the case justifies it.
It is a request rather than an entitlement.
A cross-border case with twenty years of American accounts is the kind that may warrant it.
So ask early rather than in the last week of the first 90.
Do you calculate your own penalty?
You do, and this is the part that surprises people most. HMRC's guidance says you calculate the penalty yourself, using its published factsheets, rather than waiting for HMRC to work it out and tell you. Nothing in the process does that step for you.
The factsheets set out the behaviour-based ranges.
Choosing the wrong behaviour category is the commonest reason a disclosure comes back.
In our practice this is where professional help earns its fee on a disclosure of any size.
What does HMRC offer in return?
Certainty rather than discount. The guidance says that where a disclosure is correct and complete and you cooperate fully, HMRC will not seek a higher penalty except in specific circumstances, and will not publish your details.
That is meaningful, and it is not a reduced rate.
An incomplete disclosure can lead to higher penalties, investigation and publication.
So the value of the facility lies in doing it properly rather than in the headline terms.
In short, the facility buys a known process and a measure of protection for cooperating. It does not buy a discount, and anybody describing it as one has misread the page.
When is the money due?
On the day you submit the disclosure. The guidance is explicit that full payment of the disclosed amount falls due on the submission date, and that anyone unable to pay must agree arrangements with the offshore disclosure team beforehand.
That is tighter than most people expect.
Agreeing time to pay before submitting is a normal step rather than an admission.
Our guide to HMRC time to pay sets out how those arrangements work.
So work out the figure before you submit, not after. A disclosure that arrives without the money attached, and without an arrangement in place, starts the relationship badly.
How many years does it cover?
That depends on behaviour, and the ranges are long. Where a failure was careless the assessment window stretches further back than for an innocent error, and deliberate behaviour stretches further still.
Offshore matters carry extended time limits of their own.
Working out the right number of years is part of the exercise rather than a preliminary to it.
So resist the instinct to pick a number before you have assembled the facts.
Also check which years remain open at all. Some of the oldest may sit outside the assessment window entirely, and establishing that is part of scoping the work.
How does it sit alongside a US catch-up?
The two run on separate tracks, and planning them together saves a great deal of work. An American in Britain who needs both is usually disclosing the same accounts to two authorities on different timetables with different penalty regimes.
The figures should agree, because inconsistency between them is an obvious risk.
Our guide to the Streamlined routes and their cost covers the American side.
So sequence the two deliberately rather than starting whichever one feels more urgent.
In our practice the British exercise is usually the smaller of the two in money and the tighter in time, which is the opposite of what people expect.
Is Streamlined penalty-free on both routes?
No, and the distinction matters when comparing the two systems. The Foreign Offshore route is the penalty-free one. The Domestic Offshore route charges 5% of the highest aggregate value of the relevant assets.
People use the phrase penalty-free without naming the route constantly.
Which route applies depends on where you were living, not on where the accounts are.
So check the route before relying on the word.
The Worldwide Disclosure Facility has no equivalent split. It offers one process, and the penalty depends on behaviour rather than on which side of an ocean you were living.
What information will you need?
More than a bank statement run. Each year needs the income, the gains, the exchange rates used, and the UK tax position as it should have been, reconstructed from the original documents.
American tax already paid matters, because credit relief may reduce the British liability.
Our guide to which exchange rate to use covers the conversions.
So the work is mostly archaeology, and it takes longer than the 90 days suggests.
Start with the custodian. A US broker can usually produce a decade of statements in one request, which is far quicker than rebuilding them from your own files.
Making a disclosure, step by step
A sequence that keeps the clock on your side.
- Work out which years and which sources are in scope before touching the service.
- Gather statements, dividend vouchers and completion statements for each year.
- Reconstruct the UK position for each year, with credit for American tax where due.
- Choose the behaviour category honestly and calculate the penalty from the factsheets.
- Notify HMRC, then complete within the 90 days the acknowledgement starts.
- Agree payment arrangements before submitting if the full amount is not available.
What if HMRC contacts you first?
Then the position changes, and not in your favour. A disclosure that follows HMRC opening an enquiry counts as prompted rather than unprompted, which moves the penalty ranges upward. The same facts, disclosed a month earlier, would have cost less.
The guidance says disclosures from taxpayers under enquiry go to an investigating officer.
Our guide to what happens in an HMRC enquiry covers that process.
So the value of coming forward falls sharply once a letter arrives.
Does it cover American tax too?
Not at all, and nobody should assume otherwise. This is a British facility addressing British liabilities. It leaves an American filing obligation exactly where it was, to deal with on its own terms.
The same documents serve both exercises, which is the practical overlap.
Our guide to quiet disclosure and why it fails explains what not to do on the American side.
So one disclosure does not close the other file.
So budget for two exercises. They share evidence and they do not share deadlines, penalties or forms.
An illustrative example
Consider an American who moved to Leeds a decade ago and kept a US brokerage account, reporting the income faithfully to the IRS and never to HMRC.
The British liability was real, modest in most years, and larger in two when he sold shares. His American tax already paid reduced it through credit relief.
He assembled the years first, notified, and completed inside the 90 days with a penalty calculated on a careless rather than deliberate basis.
These facts are illustrative. The shape is ordinary: the income was never hidden, it simply went to the wrong authority.
Common mistakes we see
The first notifies immediately, which starts the clock before any figures exist.
The second guesses the penalty rather than working it out from the factsheets.
The third discloses in Britain and assumes that covers the American position, which it does not.
The fourth submits without arranging payment, when full payment falls due on the submission date.
How US UK Tax Hub helps with the Worldwide Disclosure Facility
When you are disclosing US income to HMRC we assemble the years before anybody notifies, because the 90 days starts whether or not the figures exist.
We also run the British and American exercises together, so the two disclosures tell the same story about the same accounts.
Our streamlined filing service covers both sides, and fees stay fixed and agreed in writing. How we work sets out the process.
If there are British years to put right, talk to us before you notify.
