In the year an American moves to the UK, each country draws its own line. The UK decides residence for the whole tax year under the Statutory Residence Test (opens the official HMRC page in a new tab), and where one of five arrival cases applies, it splits that year into an overseas part and a UK part, so foreign income from before the move generally stays outside UK tax. The US does not split anything. Form 1040 covers the whole calendar year, and relief for UK tax starts from the move.
This post is for US citizens and green card holders arriving in the UK part way through a year, and for anyone who has just done so. It goes further than the residence section of our guide to US and UK tax returns for Americans in the UK: how the arrival cases work, how the two tax years overlap, the choice between waiting to qualify for the exclusion and claiming the credit, the state return, and the records worth keeping from the day you land.
How does the UK decide when your residence begins?
The UK does not count residence from the day you land. It asks whether you are resident for the whole tax year running from 6 April to 5 April, using the Statutory Residence Test. If you are, and you were not resident the year before, split-year treatment may then divide that year at your arrival.
HMRC's guidance note RDR3 (opens the official HMRC page in a new tab) sets out the test in three stages, applied in order. The automatic overseas tests can make you non-resident outright. The automatic UK tests can make you resident outright, for example by spending enough days here, by having your only home here for a sustained period, or by working full-time here over a year-long period. Where neither settles the answer, the sufficient ties test weighs family, accommodation, work and past presence against the days you spend in the UK.
An American who moves for a permanent job or to set up home usually becomes resident for the year of arrival. Someone arriving very late in the tax year may not, and the following year is then the first year of residence. The test is separate from the US substantial presence test, which does not apply to US citizens.
Which split-year cases apply to someone arriving in the UK?
HMRC's manual lists eight split-year cases. Cases 1 to 3 cover departures and Cases 4 to 8 cover arrivals. Each arrival case requires you to be UK resident for the tax year and not resident for the previous one, and each has further conditions that must all be met.
In most arrival cases, the part of the year before the trigger must not have produced residence through UK ties, judged against day limits scaled down for a part year. Some cases also require residence in the following tax year. Where more than one case applies, HMRC's priority rules generally choose the earliest split date.
Split-year treatment is not a separate election. The year is split if the conditions of a case are met, and GOV.UK says you state which case applies on your Self Assessment return. That entry goes on the SA109 residence pages (opens the official HMRC page in a new tab), which HMRC's free online service does not support. Our form guide to SA109 explains the pages, and our UK Self Assessment service files them.
- Case 4: you begin to have your only home or homes in the UK and keep them to the end of the tax year
- Case 5: you start full-time work in the UK that meets the full-time work test over a year-long period
- Case 6: you return after a period of full-time work overseas that made you non-resident, having lived here before
- Case 7: you join a partner who falls within Case 6, to continue living together in the UK
- Case 8: you acquire a UK home, keep it into the next tax year, and are resident in that year without a split
How do the UK tax year and the US calendar year overlap?
In the arrival year the two returns cover different slices of time. The US return covers 1 January to 31 December, including the months before the move. The UK return covers the tax year containing the arrival, and with split-year treatment, its UK part runs from the split date to 5 April.
Take a move in late summer. The US return for that calendar year includes US salary before the move and UK salary after it. The UK return for the tax year of arrival includes UK salary from the split date to the following 5 April, which reaches into the next calendar year. One stretch of UK earnings therefore sits on two US returns.
GOV.UK explains that the split means you pay UK tax on foreign income only for the period you lived here. The foreign income and gains regime (opens the official GOV.UK page in a new tab) is separate: someone not UK resident in any of the previous ten tax years can claim it for four tax years, running from the year residence starts. First-time UK filers register by 5 October after the tax year ends, and our post on Self Assessment for Americans on PAYE explains when a return is needed.
Can you claim the foreign earned income exclusion in the year you move?
Only once you meet a qualifying test, and in the year of a move that usually happens after the return is due. The foreign earned income exclusion (opens the official IRS page in a new tab) needs a foreign tax home and either bona fide residence abroad for a full tax year or physical presence abroad for a set number of days in twelve months.
The physical presence test asks for 330 full days in a foreign country within any period of twelve consecutive months. A full day runs from midnight to midnight, and days over international waters do not count. The bona fide residence test needs residence abroad for an uninterrupted period that includes an entire calendar year, so someone arriving mid-year cannot meet it until the end of the following year. Once met, either test can reach back to the year of the move.
The arrival-year exclusion is prorated: the annual maximum, $130,000 for 2025, is scaled by the qualifying days that fall in the year. It covers only earnings for work done abroad in the qualifying period, so salary for work in the US before the move stays taxable. The claim is made on Form 2555.
Publication 54 (opens the official IRS page in a new tab) gives two ways to deal with the wait. You can file by the usual date, which is 15 June for a filer living abroad, report worldwide income without the exclusion, and later claim it on Form 1040-X. Or you can apply on Form 2350, filed by the due date, for an extension that generally runs to shortly after the date you expect to qualify. Form 2350 is only for those who expect to claim the exclusion, and interest still runs on any unpaid tax.
Is the foreign tax credit the simpler route in the arrival year?
Often it is, because the foreign tax credit (opens the official IRS page in a new tab) needs no qualifying period. UK tax on the UK salary earned after the move can be credited on the first US return, without waiting for a test to be met, and unused UK tax carries forward. The exclusion is still worth comparing on the actual figures.
The credit is claimed on Form 1116 against US tax on the foreign income. UK rates are generally higher than US rates, so the UK tax on a UK salary usually covers the US tax on it, and any excess carries back one year and forward ten. The arrival year can be the exception, where early PAYE is modest and the prorated exclusion covers all the UK pay. Revoking the exclusion later bars a new election for five years without IRS consent, so a first-year choice made for convenience can bind later years. Our post on the foreign tax credit or the exclusion in the UK works through the comparison.
Take a US citizen who leaves a job in Boston and starts a permanent, full-time role in Manchester in late summer, renting a flat the same week. Having been non-resident the year before, her UK year will likely split under Case 4, 5 or 8. Her US return reports both salaries. She cannot meet the physical presence test until the following summer, so she either extends on Form 2350 or files on time claiming the credit for UK tax deducted under PAYE in that calendar year.
What happens to state tax in the year you move?
Most people leaving a state with an income tax file a part-year resident return for the year of the move. It generally taxes all income up to the date residence ended and only income from sources in the state after that. Each state applies its own residence and domicile rules.
The federal choices do not carry across. Some states do not follow the foreign earned income exclusion, and many give no credit for UK tax, so residence should end cleanly on a date the records support. Our post on leaving California or New York for London covers those two in detail, and our multi-state tax filing service prepares the part-year return alongside the federal one, so the move date is the same on every return.
What records should you keep from the day you arrive?
Keep anything that fixes a date. The UK split date, the start of the US qualifying period and the end of state residence each depend on when you arrived, started work, took a home and gave up the old one. Records made at the time beat reconstructions.
Accounts need attention from the start. A new UK current account, savings account or workplace pension counts towards the FBAR aggregate (opens the official FinCEN page in a new tab) of $10,000 for the calendar year in which it is opened, along with any US accounts. Convert sterling figures using one documented method, such as the IRS yearly average exchange rates (opens the official IRS page in a new tab) for regular pay.
Our document checklist lists what each situation needs, and our individual tax returns service prepares the arrival-year returns for both countries from one set of records. For everything else an American in the UK files each year, return to the guide to US and UK tax returns for Americans in the UK.
- Flight records and a day-by-day log of where you were, starting before the move
- The UK tenancy or purchase completion date, and the date the US home was sold or let
- The UK employment contract, its start date and a record of days worked in each country
- The final US payslip and the first UK payslips, plus the P45 or starter checklist
- Opening dates and statements for every new UK account
- The date state residence ended and the evidence behind it
General information, not advice. The right answer depends on your circumstances and the tax year concerned.
