British in the US? Your UK life follows you into the US tax net.
Once US-resident, the IRS taxes your worldwide income — including the flat you kept, the ISA you left open and the pension still growing at home. Each needs reporting, and some need restructuring.
Residency starts earlier than you think
The substantial presence test counts days across three years, and crossing it makes you a US taxpayer on everything, everywhere. The year you arrive is usually a dual-status year with planning opportunities that vanish once it is filed.
We establish your residency position, elect what should be elected, and report the UK assets US residence has just made reportable.
- Substantial presence and first-year elections
- UK rental property on a US return
- ISAs held after the move — the PFIC problem
- UK pensions under the treaty
Keep the UK side clean too
Letting a UK property means the non-resident landlord scheme and continued Self Assessment. Selling it means 60-day CGT reporting. We keep the UK filings running alongside the US ones, from one file.
What we typically handle for you
- Substantial presence and first-year election analysis
- US federal and state returns
- UK rental property on both returns
- ISA and UK fund PFIC triage after the move
- UK pension disclosure and treaty positions
- Non-resident landlord scheme registration
- 60-day CGT returns when UK property sells
- Dual-status arrival year returns
The services that usually apply
Questions we get about this
Frequently yes, because it stops being a shelter the moment you become a US taxpayer and the funds inside are usually PFICs.
Selling while still solely UK resident is generally far cleaner than unwinding the position afterwards.
Rental profit is reportable to both authorities, calculated differently, with US depreciation required and recaptured on eventual sale.
The UK non-resident landlord scheme may also apply to how tax is collected at source.
Transferring your own existing savings is not itself a taxable event - moving money is not earning it.
Large transfers can trigger reporting, and any income or gain those funds generated while you were a US taxpayer is a separate question.
Broadly once you hold a Green Card or meet the Substantial Presence Test, which counts days across the current and two preceding years on a weighted basis.
It is a mechanical test, which means it can be anticipated. Knowing where you will land before year end is far more useful than establishing it afterwards.
The pension is generally protected by the treaty as it grows. The ISA is not - the US ignores the wrapper, and the funds inside are usually PFICs.
This is the single most common thing worth restructuring before a move rather than after.
Often yes, at least for the year of departure and afterwards if you keep UK income such as rent, or realise UK gains.
Split-year treatment can divide the year of the move, but it has to be claimed and depends on facts worth recording at the time.
Last reviewed . Thresholds and rates change annually — check figures against the current tax year before relying on them.
Moving to the US, or already there?
The earlier we look at your UK assets the more options remain. Tell us what you hold.