Individuals & Families
9 services, 8 core filings, US and UK
US and UK returns for Americans in Britain, Britons in the US and households with a foot in each, including the account reporting that goes with them.
Who is the Individuals & Families division for?
Most people who come to us have one life and two tax authorities. We prepare the US and UK returns together, so that income taxed in one country is relieved correctly in the other and the reporting forms that carry the penalties are not missed.
Services in this division
- Individual Tax Returns
US federal returns for Americans living in the UK and British nationals with US income, prepared with the UK figures in view.
- UK Self Assessment
Self Assessment returns for UK residents with US income, residence questions or treaty claims, prepared with the US return in view.
- Foreign Income & FBAR
FBAR and Form 8938 reporting for UK accounts, with the income those accounts produce reported correctly on the US return.
- Cross-Border Tax
US and UK returns prepared together from one set of workpapers, so credits, tax years and exchange rates line up across both.
- US/UK Pensions
How workplace pensions, SIPPs, 401(k)s and IRAs are taxed and reported when the saver and the scheme are in different countries.
- PFIC Reporting
Form 8621 reporting and elections for US persons holding UK funds, investment trusts and non-US ETFs, inside or outside an ISA.
- IRS Streamlined Filing
Catch-up filing under the IRS Streamlined Filing Compliance Procedures for people whose missed US returns and FBARs were non-wilful.
- Cross-Border Property
US and UK tax on homes and rental property held across the two countries, including sales, currency gains, FIRPTA and UK reporting.
- Treaty Relief
Claims under the US/UK income tax treaty, with Form 8833 disclosure, residence tie-breaker analysis and reduced withholding on US income.
One household, two returns each year
A US citizen or green card holder living in the UK files a US return every year, whatever HMRC has already collected.
Most owe little or nothing once UK tax is credited, but the filing is compulsory, and the reporting that travels with it is where problems start. UK bank accounts go on the FBAR once their combined value passes $10,000. A workplace pension, an ISA and a child's savings account each have a US treatment that differs from the UK one.
Marriage to a non-US spouse changes the return. The usual status is married filing separately, which has a gross income filing threshold of $5, so almost everyone in that position has to file. An election to treat the spouse as a US resident allows a joint return, but it brings that spouse's worldwide income into the US net. Children born abroad to a US parent are often US citizens themselves, and in time they acquire filing and account reporting duties of their own.
British nationals moving to the US face the mirror image. US residence starts with a green card or with the substantial presence test, which counts days over three years and excludes days for certain students and teachers and short stops in transit. From that point worldwide income is reportable, including UK rental income, ISAs and UK funds. The UK side does not switch off on departure. The Statutory Residence Test decides when UK residence ends, and UK property income remains taxable in the UK afterwards.
What usually needs attention
- 01
- Annual Form 1040 with foreign tax credits for UK tax already paid
- 02
- FBAR and Form 8938 reporting for UK accounts, pensions and ISAs
- 03
- Filing status and elections where one spouse is not a US person
- 04
- UK Self Assessment with SA106 foreign pages and SA109 residence claims
- 05
- Catch-up filing for people who did not know they had to file
The forms this division files
Most of the work sits in a handful of returns and information forms. These are the ones we prepare most often for this group.
- Form 8938Statement of Specified Foreign Financial Assets (FATCA)
- Form 8621PFIC Shareholder Return
- SA100UK Self Assessment Tax Return
- SA109Residence, Remittance Basis etc.
Why US UK Tax Returns
The same people keep the file year after year, so elections, carryovers and treaty positions follow you from one return to the next.
One File
US and UK returns prepared in the same engagement and reconciled line by line.
Primary Sources
Every position traced to the Code, the treaty, IRS instructions or HMRC guidance.
Scope First
Returns, forms, years and fee agreed in writing before work begins.
The Same People
The team that files this year carries the elections and credits into the next.
Questions we are asked
I pay tax in the UK through PAYE. Do I still have to file a US return?
Generally yes. The US taxes its citizens and green card holders on worldwide income wherever they live, and the filing requirement depends on gross income and filing status, not on whether tax is due. UK tax paid through PAYE is normally claimed as a foreign tax credit, which often reduces the US liability on that salary to nil. The return and the account reporting are still required.
My husband is British and has never lived in the US. Does his income go on my return?
Not by default. A US citizen married to a non-US spouse normally files as married filing separately and reports only their own income, although jointly held accounts are reportable in full on the FBAR. You can elect to treat your husband as a US resident and file jointly, which brings his worldwide income into the US return. Whether that helps depends on both incomes and on the assets he holds.
When are the US deadlines if I live in the UK?
The standard due date is 15 April. Filers living outside the US receive an automatic extension to 15 June, and Form 4868 extends the filing date to 15 October. Interest on any tax owed still runs from the original due date. The FBAR is due 15 April, extended automatically to 15 October. UK Self Assessment keeps its own calendar, with online returns due by 31 January after the tax year ends.
I have never filed a US return. How serious is that?
It depends on why the returns were missed. Where the failure was non-wilful, the IRS Streamlined Foreign Offshore Procedures allow a taxpayer living abroad to file three years of returns and six years of FBARs, and that Foreign route carries no penalty. The non-wilful conduct has to be certified in writing, and the route closes once the IRS opens an examination. Eligibility turns on your residence history and the facts behind the missed filings.
I am British and spend part of each year in the US. When do I become a US tax resident?
Without a green card, the test is substantial presence: at least 31 days in the current year and a weighted total of 183 days, counting all current-year days, a third of the prior year and a sixth of the year before. Some days are excluded, including days for certain students, teachers and diplomats and short stops in transit. The closer connection exception and the treaty tie-breaker are separate reliefs, each with its own conditions and filings.
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