Behind on US Taxes in the UK: IRS Streamlined Filing, Accidental Americans and Renunciation

Do I have to file US taxes if I live in the UK?

Yes, if you are a US citizen or green card holder and your worldwide income is above the filing threshold for your status. The United States taxes by citizenship as well as residence, so living in the UK and paying UK tax do not remove the duty to file a US return each year.

The United States is one of very few countries that taxes its citizens wherever they live. The IRS position on US citizens and resident aliens abroad (opens the official IRS page in a new tab) is that they follow the same filing rules as people at home. Worldwide income goes on Form 1040 each year, in dollars, whatever a UK employer or HMRC has already done with it.

The duty turns on gross income, measured before any exclusion or credit. For tax year 2025 the thresholds broadly follow the standard deduction, which is $15,750 for a single filer. Two lower thresholds catch many people in the UK. A US citizen married to a non-US spouse normally files as married filing separately, where the threshold is $5. Self-employed people must file at a much lower level of net earnings than employees. Publication 54 (opens the official IRS page in a new tab) sets out the rules for filers abroad.

Having to file is not the same as having tax to pay

UK income tax is usually higher than US tax on the same income, so the foreign tax credit or the foreign earned income exclusion often reduces the US bill on a UK salary to nothing. Those reliefs are claimed on a return. They do not operate automatically, and a person who has never filed has never claimed them. Our guide to US tax returns for Americans in the UK covers the annual return in full. This guide is about the years that were missed.

• An FBAR, filed with FinCEN, when foreign accounts together exceed $10,000 at any time in the year
• Form 8938, filed with the return, when foreign financial assets pass higher thresholds
• Form 8621 for each passive foreign investment company, which usually means UK funds
• Forms 3520 and 5471 for foreign trusts, large foreign gifts and UK companies

The US-UK tax treaty does not switch the duty off. It contains a saving clause that lets the United States tax its citizens broadly as if the treaty did not exist, subject to a list of exceptions. The treaty decides which country gives way on particular income, and our guide to US-UK double taxation explains how. It does not excuse a citizen from filing.

What is an accidental American?

An accidental American is someone who holds US citizenship without having chosen it or lived as an American: typically a person born in the United States who left as a child, or a person born abroad to a US citizen parent. Citizenship carries the same US filing duty for them as for anyone else.

The term has no legal meaning, and tax law treats an accidental citizen exactly as it treats one who grew up in Ohio. It describes how the problem arises: a person who has always thought of themselves as British finds out, often in mid-life, that the United States regards them as one of its taxpayers.

Born in the United States

Almost everyone born on US soil is a citizen from birth. Citizenship does not lapse through absence or through letting a US passport expire. It ends only through a formal act of renunciation or relinquishment, discussed later in this guide.

Born abroad to a US parent

Citizenship by descent is not automatic in every case. It depends on the law in force on the date of birth, whether one or both parents were citizens, whether they were married, and how long the American parent had lived in the United States before the child was born. Some people who assume they are citizens are not, and some who have never held a US passport are. This is a nationality question to settle before any return is prepared.

Green card holders who left

A lawful permanent resident remains a US tax resident until the status is formally abandoned, revoked or ended by a court. An expired card, or years living in Manchester, does not end it for tax purposes. A treaty claim to be treated as UK resident is possible in some cases, but it has to be disclosed on a return, and for someone who has held the card in at least eight of the last fifteen tax years it can itself count as expatriation.

What does a FATCA letter from a UK bank mean?

A FATCA letter means your UK bank has found a sign of US status, usually a US place of birth, and must establish whether you are a US person. It asks you to self-certify your tax residence and citizenship and to give a US taxpayer identification number. If you are a US person, the account is reported.

The Foreign Account Tax Compliance Act (opens the official IRS page in a new tab) requires financial institutions outside the United States to identify accounts held by US persons. The UK implemented it through an agreement with the US, under which UK banks, building societies, investment platforms and insurers report to HMRC, and HMRC passes the data to the IRS. HMRC describes the framework in its guidance on the automatic exchange of information (opens the official HMRC page in a new tab).

Banks look for indicators: a US place of birth on a passport, a US address or telephone number, standing instructions to pay a US account. When one appears, the bank asks for a self-certification. For a US citizen that means declaring the citizenship and supplying a Social Security number.

How to answer it truthfully

• Establish your status first. Birth in the US almost always means citizenship; a US parent may or may not
• If you are a US citizen, say so. The form is a signed declaration
• If you have no Social Security number, say that you are applying for one and give it when issued
• If you gave up citizenship, supply the Certificate of Loss of Nationality

Declaring that you are not a US person when you are is the one response that makes the position worse. A false declaration is also a fact that sits badly in any later assessment of whether US failures were wilful, and both streamlined routes depend on conduct that was not.

A letter from a UK bank is not contact from the IRS and does not, by itself, close any of the catch-up routes. Ignoring it risks the bank restricting or closing the account. Our guide to FBAR and FATCA reporting in the UK explains what the bank reports and what you report yourself, and the foreign income and FBAR service covers the filings.

What happens if you do not file US taxes while living abroad?

Nothing may happen for years, but the exposure grows. Unfiled returns never start the time limit for the IRS to assess tax, information return and FBAR penalties accumulate year by year, refunds and credits lapse, and the favourable catch-up routes close permanently on the day the IRS opens an examination.

A UK resident whose US tax is covered by UK tax may owe little or nothing on the return itself, and penalties calculated on unpaid tax follow that figure. The larger exposure is in the information returns, where penalties are fixed or proportional and do not depend on any tax being due. A director and owner of a small UK company can owe no US tax and still face a Form 5471 penalty for each year missed.

FBAR penalties sit under a different statute and are not tax penalties. We do not quote the amounts, which change annually. For non-wilful failures, the Supreme Court held in Bittner v. United States in 2023 that the penalty applies per report, not per account, which limits the exposure of a person with many small accounts. For wilful failures the penalties are of a different order and criminal prosecution is possible.

The costs that are not penalties

• Refunds and refundable credits for old years lapse once the claim period has run
• A seriously delinquent assessed tax debt can lead to a US passport being refused or revoked
• The five-year compliance certification needed to leave the US system cleanly cannot be signed
• The streamlined procedures stop being available once an examination starts

The last point decides most cases. The choice today is between a procedure with published terms and a later conversation on the IRS's terms. Where a notice has already arrived, read our pages on IRS representation before replying, because what the notice is determines which routes remain.

What are the options for catching up on unfiled US tax returns?

There are seven routes in practice: the Streamlined Foreign Offshore Procedures, the Streamlined Domestic Offshore Procedures, late FBAR filing with an explanation, the delinquent international information return procedures, quiet or prospective filing, the IRS Criminal Investigation voluntary disclosure practice for wilful cases, and relief procedures for certain former citizens. Conduct and residence decide which applies.

How the decision usually runs

1. 01

   Confirm status

   Establish that you are a US citizen or resident for tax purposes, and from when.

2. 02

   Check for IRS contact

   A civil examination or criminal investigation for any year closes both streamlined routes. Ordinary notices may not.

3. 03

   Assess conduct honestly

   Write down what you knew, when, and what you did next. If the account does not support non-wilfulness, the streamlined routes are the wrong tool.

4. 04

   Apply the residence test

   Meeting the non-residency test in one of the three most recent years points to the Foreign route. Failing it points to the Domestic route.

5. 05

   Check whether income was missed

   If every year's return was filed and all income taxed, a narrower late filing of FBARs or information returns may be enough.

The streamlined filing compliance procedures (opens the official IRS page in a new tab) are the usual answer for a UK resident who simply did not know. Our shorter article on how the two streamlined routes differ is a quicker summary of the same comparison.

Who qualifies for the Streamlined Foreign Offshore Procedures?

An individual qualifies for the Streamlined Foreign Offshore Procedures if they meet the non-residency test, their failures to report income, pay tax and file FBARs were non-wilful, the IRS has not begun a civil examination or criminal investigation for any year, and they have a valid taxpayer identification number.

The procedures are open to individuals and their estates. The IRS sets out four conditions on its page for US taxpayers residing outside the United States (opens the official IRS page in a new tab), and each has to be met on the date of submission.

The non-residency test

For a US citizen or green card holder, the test is met if, in at least one of the most recent three years for which the US return due date has passed, the person had no US abode and was physically outside the United States for at least 330 full days. Visits to family in the US are compatible with the test provided the day count holds, and the IRS says that keeping a dwelling in the US does not by itself mean having an abode there. On a joint return, both spouses must meet the test.

The examination bar

The bar is wide. A civil examination of any return for any year disqualifies the person, whether or not it concerns foreign accounts. A criminal investigation does the same. A FATCA letter from a bank does not, and nor does a routine computer notice about a balance. Any IRS letter should be read by someone who can tell the difference before a route is chosen.

A worked example: a software engineer held a green card for six years, then moved back to Edinburgh and let the card expire in a drawer. He never filed the form to abandon it and stopped filing US returns when he left. He is still a US tax resident. He has lived wholly in the UK for the last three years, so he meets the non-residency test, and his failure to file looks like a misunderstanding of how the status ends. The Foreign route is likely to fit, and the IRS streamlined filing service would start by confirming his dates.

What does non-wilful mean for IRS streamlined filing?

The IRS defines non-wilful conduct as conduct due to negligence, inadvertence or mistake, or conduct that results from a good faith misunderstanding of what the law requires. The taxpayer certifies this in writing, under penalty of perjury, with a narrative of specific facts. Knowing of the duty and ignoring it is not non-wilful.

Wilfulness is not defined by what a person says about their state of mind. In the FBAR case law it reaches beyond deliberate concealment to recklessness and to wilful blindness, meaning a conscious effort to avoid learning what the rules required. Someone who suspected a duty and chose not to ask can be found wilful. Someone who had no reason to suspect one, and acted reasonably once they found out, generally is not.

How the certification narrative is written

The Foreign route uses Form 14653 and the Domestic route Form 14654. Each asks for the specific reasons for the failures, and the IRS form itself tells the taxpayer to give the whole story, favourable and unfavourable. A statement that says only that the taxpayer was unaware of the requirements is a conclusion.

• Personal background: where you were born, when you left, education and occupation
• Your connection with the US: passports held, visits, family, any US accounts or income
• The source of the money in each foreign account, such as salary, inheritance or a house sale
• What professional advice you had, from whom, and what you told them
• How and when you learned of the duty, and what you did afterwards
• Anything unhelpful, stated plainly, with the context that explains it

Where we think the streamlined route does not fit, we say so before anything is submitted. Cases with real wilfulness risk are handled with a US tax attorney, and our tax controversy page explains how that work is organised.

What do you file in a streamlined submission?

A Streamlined Foreign Offshore submission contains US tax returns for the most recent three years whose due dates have passed, with every required information return attached, FBARs for the most recent six years, a signed Form 14653 certification, and payment of all tax due with interest. The returns go to the IRS on paper.

The look-back is fixed by due dates. The return years are the three most recent for which the due date, or a properly extended due date, has passed. The FBAR years are the six most recent for which the FBAR due date has passed. A filer abroad has an automatic extension to 15 June for the return, and the FBAR is due on 15 April, extended automatically to 15 October, so the exact years depend on the month the package is sent.

1. 01

   Gather six years of account records

   List every non-US account you owned or could sign on: current and savings accounts, ISAs, pensions, investment platforms, joint accounts and accounts held for children. Find the highest balance of each in every year.

2. 02

   Assemble three years of income

   Collect P60s, P45s, Self Assessment returns, dividend vouchers, interest certificates, rental accounts, pension statements and records of any sales of shares, funds or property.

3. 03

   Prepare the three returns

   Each Form 1040 is prepared in full, or a Form 1040-X where a return was filed but was incomplete. The IRS asks for the route name to be written in red at the top of each.

4. 04

   Attach every information return

   That means Form 8938 where the thresholds are met, Form 8621 for each fund that is a PFIC, Form 3520 for foreign trusts and large foreign gifts, and Form 5471 for a UK company.

5. 05

   File six FBARs through FinCEN

   Each FBAR is filed electronically on the BSA E-Filing System. The reason for late filing is given as other, with a note that it is part of a streamlined submission.

6. 06

   Draft and sign the certification

   Form 14653 confirms eligibility, the non-residency facts with day counts for each year, and the narrative of non-wilful conduct. It carries an original signature.

7. 07

   Calculate and pay tax and interest

   Payment of the full tax shown on the three returns, with statutory interest, goes with the submission.

Why the information returns take the time

The three Forms 1040 are rarely the hard part. A stocks and shares ISA holding eight funds can mean eight Forms 8621 a year. The article on why a stocks and shares ISA worries the IRS explains the fund problem, and the PFIC reporting service covers the calculations.

How much tax will I owe under the streamlined procedures?

Often little or none for someone resident in the UK with ordinary employment income, because UK income tax usually exceeds the US tax and is credited against it. Tax does arise where the UK does not tax the income or taxes it differently: funds in ISAs, some pension events, a home sale, self-employment and investment income.

Under the Foreign route the cost is the tax on the three returns plus interest. For a UK employee whose only income is a salary, the three returns frequently show nothing due once a foreign tax credit (opens the official IRS page in a new tab) is claimed for UK income tax. That is the common result, and it is not guaranteed.

Credit or exclusion on the late returns

Two reliefs do most of the work. The foreign tax credit on Form 1116 sets UK tax against US tax on the same income. The foreign earned income exclusion on Form 2555 removes up to $130,000 of earnings for tax year 2025. In the UK, where rates are generally higher, the credit often gives the better result and leaves carryovers for later. The exclusion is not the default, and whether it can still be elected on a late return depends on conditions in the regulations that we check before relying on it.

ISAs have no US tax protection. Interest, dividends and gains inside them are taxable in the US as they arise, and collective funds held in them are commonly passive foreign investment companies with punitive default treatment. UK pensions are treated more kindly: growth inside a UK pension is generally protected by the treaty for a US citizen, while relief for contributions is narrower and limited by the saving clause.

A UK home sale that is fully relieved in the UK can still produce a US gain. The US has its own main home exclusion with its own ownership and use tests, and the gain is measured in dollars, so exchange rate movement over a long ownership period can add to it. Self-employed people face US self-employment tax at 15.3% unless they show they are covered by UK National Insurance under the totalization agreement (opens the official SSA page in a new tab), which normally requires a certificate of coverage from HMRC.

How does the Streamlined Domestic Offshore route work?

The Streamlined Domestic Offshore Procedures are for non-wilful taxpayers who do not meet the non-residency test, usually because they live in the United States. They must already have filed returns for the three most recent years, so they file amended returns, and they pay a 5% miscellaneous offshore penalty on the relevant foreign assets.

This is the route for the British national who moved to Boston and kept UK accounts off the US return, and for the American who came home after years in London and never mentioned the pension and savings left behind. The IRS page for US taxpayers residing in the United States (opens the official IRS page in a new tab) sets out the conditions. The conduct standard is the same as on the Foreign route, and so is the examination bar.

How the penalty base is worked out

The 5% is applied to a single figure: the highest aggregate year-end value of the foreign financial assets subject to the penalty, taken across the years in the covered return period and the covered FBAR period. An asset is in the base if it should have been reported on an FBAR or on Form 8938 and was not, or if it was reported but the income from it was left off the return. Assets that were fully and correctly reported are outside it.

A second worked example: a nurse from Cardiff moved to Chicago on a work visa, became a US tax resident through presence, and filed US returns every year through a high street preparer who never asked about foreign accounts. She kept a UK current account, a cash ISA and a small inherited share portfolio, none of which appeared on her returns. She fails the non-residency test because she lives in the US. Her returns were filed, so the Domestic route is open: amended returns adding the UK income, FBARs, Form 14654, and the penalty on the highest year-end total.

The penalty replaces the accuracy-related, information return and FBAR penalties that could otherwise apply to the same failures. Interest is still charged on the tax itself.

What if I only missed FBARs or information returns?

If your US returns were filed on time and reported all your income, and only FBARs or international information returns were missed, the streamlined procedures may be more than you need. Late FBARs can be filed through FinCEN with an explanation, and late information returns under the delinquent international information return submission procedures. Neither guarantees that no penalty follows.

Late FBARs

A late FBAR (opens the official FinCEN page in a new tab) is filed electronically in the ordinary way, with a reason for lateness selected on the form. For years the IRS published separate delinquent FBAR submission procedures stating that it would not impose a penalty where the income from the accounts had been reported and taxed and the filer had not been contacted. That page was withdrawn in 2026. The current IRS guidance on the FBAR (opens the official IRS page in a new tab) says that late filing is a violation, that penalties depend on the facts and circumstances, and that filing promptly before any IRS contact keeps exposure to a minimum.

The practical step is unchanged: file the missing reports promptly and accurately, with a truthful explanation. With no published assurance to rely on, that explanation deserves the same care as a streamlined narrative. Our article on whether you file an FBAR or Form 8938 covers which report applies to which accounts.

Late information returns

The delinquent international information return submission procedures (opens the official IRS page in a new tab) are open to a taxpayer who is not under civil examination or criminal investigation and has not already been contacted by the IRS about the missing forms. Most forms are attached to an amended return. Forms 3520 and 3520-A are filed separately. A reasonable cause statement can be attached, but the IRS says that penalties may be assessed under its existing procedures, sometimes before the statement is read.

Quiet and prospective filing

Two informal approaches are sometimes suggested. A quiet disclosure means sending in late or amended returns through the normal channels with no procedure and no certification. Prospective filing means starting to file from this year and leaving the past alone. The first invites exactly the penalties the streamlined routes would have avoided. The second leaves every earlier year open and makes the eventual explanation harder, because the filer now plainly knows the rules.

The IRS has said that penalties assessed after a quiet disclosure will not be abated if the taxpayer later turns to the streamlined procedures. We do not recommend either informal route where income went unreported. Where the facts fit a narrow late filing, we say so, and the individual tax returns page describes how ongoing filing is then kept in order.

Does the streamlined procedure protect you from an audit?

No. A streamlined submission is not a closing agreement. The IRS does not acknowledge receipt, the returns are processed like any others, and they can be selected for examination. If an examination finds the original failures were fraudulent or the FBAR violations wilful, the penalty protection is lost and further penalties, or prosecution, remain possible.

The older offshore voluntary disclosure programmes ended with a signed closing agreement that settled the years concerned. The streamlined procedures were designed as a lighter process and do not. What the taxpayer receives is a statement of IRS practice: someone who is eligible and follows the instructions will not be charged the listed penalties. That statement has been reliable. It is conditional on the certification being true.

What happens after you post it

There is no acceptance letter. The payment is cashed, the returns are entered on the account, and in most cases nothing else arrives. Some submissions draw a letter asking for more detail on the certification, usually where the narrative was thin or the accounts were large. A small number are examined. The returns are open to examination for the normal period from filing, and longer where a required information return was left out.

Staying compliant afterwards

• File each year's return by 15 June, or extend to 15 October
• File the FBAR every year the $10,000 aggregate threshold is passed
• Keep the information returns going for every fund, trust and company
• Tell the preparer about new accounts, inheritances, gifts and property sales as they happen

The procedure can realistically be used once. A second lapse after a streamlined submission is very difficult to describe as non-wilful, because the earlier certification proves the taxpayer knew the rules. Later returns are filed in the normal way, electronically where possible, and the first of them should be consistent with the three years that went in the package.

How do accidental Americans without a Social Security number catch up?

A US citizen needs a Social Security number to file returns and to use the streamlined procedures, so an accidental American without one applies for it first. Applications from the UK go through the Federal Benefits Unit at the US Embassy in London. People who have already relinquished citizenship may qualify for separate relief that needs no number.

The streamlined instructions require a valid taxpayer identification number on every return. For a US citizen that is a Social Security number. An individual taxpayer identification number (opens the official IRS page in a new tab) is for people who are not eligible for a Social Security number, which a citizen always is, so the ITIN is not an alternative.

Applying from the UK

1. 01

   Prove citizenship

   A US birth certificate, a US passport or a Consular Report of Birth Abroad. Those claiming through a parent may need the parent's records as well.

2. 02

   Prove identity and age

   Normally a current passport, British or American.

3. 03

   Show where you have lived

   Adult first-time applicants are asked for evidence that they have lived outside the US, such as school, employment and tax records, to explain why no number was issued earlier.

4. 04

   Apply through the Federal Benefits Unit

   The unit at the US Embassy in London handles applications for UK residents. Adults applying for a first number are generally asked to attend in person.

If you have already given up citizenship

The relief procedures for certain former citizens (opens the official IRS page in a new tab) were written for accidental Americans who relinquished citizenship without ever having filed. They apply to people who relinquished after 18 March 2010, have no history of filing as a US citizen or resident, had a net worth below $2 million both at expatriation and at the time of the submission, and whose total tax for the year of expatriation and the five before it falls under a low ceiling set by the IRS. The failures must have been non-wilful.

• Six years of returns are filed: the year of expatriation and the five before it
• No Social Security number is required for this procedure alone
• If every condition is met, the tax for those years is not collected and no penalty is charged

The IRS has set no end date for this relief, though it can be withdrawn. For those who do not qualify, the usual sequence is a Social Security number, a streamlined submission, and then the decision about renunciation covered in the next section. Our individuals and families team handles both sequences.

Can you renounce US citizenship after catching up on taxes?

Yes. Renunciation is a State Department process that does not itself require tax compliance, but the tax consequences do. To avoid covered expatriate status a person must certify on Form 8854 that they complied with US tax law for the five preceding years. Renunciation ends future obligations and leaves past ones in place.

The State Department handles the loss of nationality: an appointment at the embassy or a consulate, an oath, a fee, and in due course a Certificate of Loss of Nationality. It does not ask whether tax returns are up to date. The IRS handles the expatriation tax (opens the official IRS page in a new tab) rules, and it is there that an unfiled history becomes a problem.

The five-year certification

Form 8854 is the expatriation statement filed with the return for the year of renunciation. It asks the person to certify, under penalty of perjury, that they have complied with all US federal tax obligations for the five tax years before the year of expatriation. Someone who cannot make that certification is a covered expatriate by that fact alone. Net worth and income are irrelevant to this test.

The streamlined procedures cover three years of returns, and the certification covers five. Where renunciation is the aim, the catch-up work is scoped with Form 8854 in mind, so that no unfiled year is left inside the certification period.

1. 01

   Catch up first

   Bring returns and FBARs into compliance through the route that fits, and file any further years the five-year certification needs.

2. 02

   Test covered expatriate status

   Measure net worth and the five-year average tax liability before the appointment, while there is still time to plan.

3. 03

   Attend the appointment

   Citizenship is treated as relinquished on the date of the oath, provided the State Department later confirms it with the certificate.

4. 04

   File the final returns

   The year of expatriation needs a dual-status return covering the part-year as a citizen and the part-year as a non-resident, with Form 8854 attached.

What renunciation does not do

It does not cancel tax, penalties or filing duties for the years when the person was a citizen. Those years remain open to assessment on the normal rules, and where no return was ever filed the time limit has not started. Nor does it end liability to US tax on US-source income afterwards, which is then taxed on the non-resident basis.

Who pays the US exit tax when renouncing citizenship?

Only covered expatriates. For expatriations in 2025, a person is covered if net worth is $2 million or more, if average annual net income tax for the five prior years exceeds $206,000, or if they cannot certify five years of tax compliance on Form 8854. Meeting any one test is enough.

The mark-to-market regime

A covered expatriate is treated as having sold all their worldwide property at market value on the day before the expatriation date. The resulting net gain is taxable to the extent it exceeds an exclusion of $890,000 for 2025 expatriations.

• Deferred compensation, which can include pensions, follows separate rules and may be taxed as if paid out or subjected to withholding on later payments
• Gifts and bequests from a covered expatriate to US persons can be taxed in the recipient's hands

The two exceptions

Two groups are excused from the net worth and tax liability tests. The first is a person who became at birth a citizen of both the US and another country, is still a citizen of that other country and taxed as a resident there, and has been a US resident for no more than ten of the last fifteen tax years. The second is a person who relinquishes before the age of eighteen and a half and has been a US resident for no more than ten tax years. Neither group is excused from the certification.

A third worked example: a solicitor born in Boston to a British mother has been both American and British since birth, has lived in England since infancy and is taxed there as a resident. His house and pension together exceed the net worth test. He qualifies for the dual citizen exception, so the net worth test is set aside. If he has filed and can certify five years of compliance, he is not a covered expatriate and no exit tax arises. If he renounces with unfiled years, the exception is lost and the full regime applies to the house and the pension.

Founders, fund managers and executives with unvested equity or carried interest have additional valuation questions, which our guide to US-UK tax for founders, fund managers and executives takes further.

What changes on the UK side when you catch up or renounce?

Very little changes automatically. UK tax depends on residence under the Statutory Residence Test, so a UK resident keeps paying UK tax as before. Catching up with the IRS does nothing for any UK omission, and renouncing changes how US-source income, US assets and UK bank reporting are treated afterwards.

HMRC takes no interest in a person's US filing history as such. UK liability follows residence, decided by the Statutory Residence Test (opens the official HMRC page in a new tab), and a US citizen resident in the UK is taxed on the same basis before and after a streamlined submission or a renunciation. The catch-up work does, however, tend to bring UK questions to the surface.

While catching up

• US bank interest, US dividends and rent from US property are taxable in the UK for a UK resident and are often missing from UK returns
• US tax found to be due on the late returns may be creditable in the UK, or the UK tax creditable in the US, depending on the income
• Time limits for amending UK returns and claiming relief are shorter than the US look-back

Where UK tax was underpaid on overseas income, HMRC has its own disclosure route, described in its guidance on how to tell HMRC about underpaid tax from previous years (opens the official HMRC page in a new tab). UK penalties turn on the behaviour behind the error and on whether the disclosure was prompted. The two corrections are best prepared from one set of figures.

After renouncing