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The US & UK Tax Problems You Might Be Facing

Expat professionals and investors moving between the US and UK face constant confusion: residency rules that conflict, LLCs taxed the wrong way, PFIC traps on investments, and property structures that trigger double taxation.

I solve this using a structured US–UK Expat Tax Blueprint that clarifies residency, entity classification, asset positioning, and cross-border property exposure. It removes risk, optimises tax outcomes, and ensures you only pay the right tax, in the right country, once.

Living between the US and the UK creates one of the most complex tax situations in the world. A single incorrect assumption can lead to:

  • Dual tax residency without knowing

  • LLCs taxed twice (once in each country)

  • PFIC penalties of 40%+ on UK investments

  • Mistimed capital gains triggering double tax with FIRPTA or NRCGT withholding tax on property sales

Most expats only realise the danger after HMRC or the IRS send a letter.

By then, the damage is done and costly.

  • You don’t need more forms.
  • You need a strategy.

 

 

The Solution: The US–UK Expat Tax Blueprint

I deliver a structured, four-module advisory framework designed specifically for US citizens in the UK, UK citizens with US investments, global executives with RSUs, and cross-border property owners.

This Blueprint fixes the four root causes of double taxation:

Understand exactly where you are taxed, and why.

Covers:

  • UK Statutory Residence Test (SRT)

  • US Substantial Presence Test (SPT)

  • Treaty tie-breaker rules

  • Where income is taxed

  • What filings are required

Outcome:
You avoid being “tax resident” in both countries accidentally — the most common (and most expensive) issue for expats.

Fix LLC/Ltd mismatches and prevent double tax.

Covers:

  • LLC treatment in the UK (transparent vs opaque)

  • Ltd treatment in the US (PFIC/GILTI risk)

  • Partnership classifications

  • Structuring income flows correctly

Outcome:
You prevent LLCs or Ltds being taxed twice — and avoid PFIC/GILTI penalties created by misclassification.

Protect your portfolio from PFIC penalties and CGT timing mismatches.

Covers:

  • Worldwide income mapping

  • Capital gains timing (UK vs US)

  • PFIC avoidance for US persons in the UK

  • ISA/OEIC dangers

  • Efficient asset-holding structures

Outcome:
You avoid 40%+ PFIC tax rates, structure investments correctly, and time disposals to reduce tax across both systems.

Own and sell property without losing money to withholding regimes.

Covers:

  • UK property owned by US residents

  • US property owned by UK residents

  • LLC vs Ltd vs personal ownership

  • FIRPTA withholding

  • UK Non-Resident CGT

  • Rental income allocation

Outcome:
You eliminate unnecessary withholding taxes and structure global real estate properly from day one.

Who is this for?

This Blueprint is ideal if you are:

  • A US citizen living in the UK

  • A UK resident with a US LLC or US investments

  • A global executive with RSU/stock compensation

  • A cross-border landlord with property in both countries

  • A dual resident investor needing treaty clarity

  • An IFA, mortgage broker, attorney or CPA with clients in this corridor

If you have income, investments or property across these two jurisdictions, this framework is built for you.

US citizens living in the UK must manage two tax systems that often conflict. We help you stay compliant in both countries and avoid double taxation with a single coordinated strategy.

✅ We help you with:

  • Coordinating IRS and HMRC reporting correctly

  • Aligning US and UK tax residency rules

  • Applying foreign tax credits to avoid double taxation

  • Structuring employment, property, and investments tax-efficiently

  • Filing accurate US returns even when tax is already paid in the UK

❌ Common problems we fix:

  • Assuming UK residency ends US filing obligations

  • UK accountants misunderstanding US worldwide taxation

  • US CPAs ignoring UK statutory residence rules

  • Filing in one country without considering the impact on the other

UK investments are often taxed differently by the IRS, creating confusion and unexpected liabilities. We ensure your UK assets are reported correctly and structured tax-efficiently.

✅ We help you with:

  • Reporting UK property income and gains to the IRS

  • Aligning UK investments with the correct US tax treatment

  • Structuring pensions, ISAs, and UK funds safely

  • Applying treaty reliefs and foreign tax credits

  • Identifying high-risk investments before they cause issues

❌ Common problems we fix:

  • Assuming UK tax rules automatically apply in the US

  • Holding ISAs or UK funds without understanding US consequences

  • Incorrect reporting of foreign rental income or assets

  • Paying tax twice due to uncoordinated filings

Relocating to the US while retaining UK ties creates complex cross-border tax responsibilities. We help you stay compliant and ensure both countries’ filings remain aligned.

✅ We help you with:

  • Establishing correct US tax residency

  • Coordinating HMRC and IRS filing obligations

  • Managing UK property, pensions, and income correctly

  • Preventing mismatched reporting between both systems

  • Ensuring both countries recognise the right taxes and reliefs

❌ Common problems we fix:

  • Assuming UK reporting stops when you move

  • Forgetting UK CGT rules on UK property sales

  • Not reporting UK income to the IRS

  • Applying UK remittance concepts incorrectly in the US

Owning US investments while being UK-resident requires careful coordination of US withholding rules and UK tax requirements. We ensure income and gains are taxed correctly in both countries.

✅ We help you with:

  • Structuring US investments to reduce UK tax impact

  • Claiming foreign tax credits efficiently

  • Understanding US withholding rules (including FIRPTA)

  • Managing rental income, dividends, and gains across borders

  • Ensuring IRS and HMRC filings match and support each other

❌ Common problems we fix:

  • Not reporting US income to HMRC

  • Failing to reclaim excess US withholding tax

  • Using inefficient US property ownership structures

  • Confusion over federal vs state tax rules

How It Works (Our Services)

This is an 15-minute no obligation call that you can book using this calendar link to discuss your US/UK tax affairs. 

Sometimes, discussing your situation may provide comfort that you are dealing with the matter even though an immediate solution does not uncover itself in the first call.

We can discuss options of preparing tax advice and preparation of US or UK tax returns for you personally or for your companies.

We discuss the available options and agree next steps, which is usually a 60-minute tax consultation.

We offer W-7 ITIN application assistance tailored for accountants and tax firms supporting clients with U.S. tax requirements.

As IRS-authorised Certified Acceptance Agents (CAAs), we support EAs, CPAs, and UK accountants in simplifying ITIN applications by ensuring accuracy, faster processing, and full compliance. Our services cover identity verification, form preparation, and direct communication with the IRS, helping firms reduce administrative workload. This allows accountants to confidently provide ITIN assistance under their own brand, enhancing client satisfaction and delivering added value without the need for additional in-house resources.

This white-label solution enables firms to seamlessly expand their US tax services while maintaining professional standards and regulatory compliance.

You can book a call to get your US tax ID (ITIN) using our online calendar link or visit our ITIN webpage for more details

You may opt for a 60-minute tax consultation with Simon Misiewicz our US & UK Expat Tax Specialist

Before the call, Simon will review all the notes & documents that you upload and will create a bespoke tax-saving plan.

During the tax call, he will discuss the identified tax solutions with you. He will help you build a bespoke action plan you can quickly implement. 

After the meeting, Simon will email the tax-saving action plan and the video recording. He will also answer any questions about the tax saving meeting within three working days.

You can book this US-UK Expat Tax consultation using our online calendar link. 

Setting up a UK Limited Company requires more than just registering at Companies House; the structure must align with your tax residency, income sources, and long-term plans. We guide you through every step, ensuring the company is formed correctly, compliant from day one, and optimised for cross-border tax treatment.

What we do for you:

✅ Advise on share structure, directors, PSC requirements and ownership
✅ Register the company with Companies House and HMRC
✅ Set up corporation tax, PAYE, VAT (if required) and bookkeeping systems
✅ Ensure your UK company integrates properly with US filing and reporting rules
❌ No guesswork, no mismatched filings, and no unintended UK/US double taxation

You can book a meeting with us now if you wish to proceed quickly to set up a UK limited company through our online calendar

We work with a strategic partner called Doola when clients wish to set up a US LLC or C-Corporation requires more than simply registering a business — the structure must be aligned with your residency, tax treaty position, and long-term cross-border plans. We ensure your entity is formed correctly, classified properly, and integrated with both the IRS and HMRC so you avoid double taxation and future compliance problems.

What we do for you:
✅ Advise whether an LLC, LLP, or C-Corporation is the most suitable structure
✅ Form the entity in the correct state based on your business model
✅ Obtain the EIN and ITIN (if required) and complete responsible-party requirements
✅ Prepare and file “check-the-box” elections where needed to prevent double taxation
✅ Set up governance, bylaws, registered agent services, and compliance processes
✅ Align salary, dividends, and profit extraction with your UK residency position
❌ Prevent the common traps where LLCs or C-Corporations are taxed twice once in the US and again in the UK

You can go to Doola now to set up your very own LLC or C Corporation or visit our US company formation website page for more details.

The W-8BEN form allows non-US individuals to claim reduced withholding tax rates on US income, but only if the form is completed correctly and supported by the right treaty article. We help you complete the W-8BEN accurately, apply the correct tax treaty provisions, and ensure the IRS rules are met so your withholding drops from the default 30% to the treaty-reduced rate of 15%.

What we do for you:
✅ Identify whether you qualify for reduced withholding under the US-UK tax treaty
✅ Complete and submit the W-8BEN form correctly to the payer or financial institution
✅ Apply the correct treaty article to ensure 15% withholding is accepted
✅ Guide you through US-source dividends, interest, royalties, and investment income
❌ Prevent rejected forms, continued 30% withholding, and unnecessary delays or overpayments

You can book your meeting with us to discuss your W-8 BEN form using our online calendar link or visit our W-8 BEN website page for more details. 

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Q&A

Question & Answers

Do I need to file a US tax return if I live in the UK?

Yes. US citizens and green card holders must file a US tax return every year, no matter where they live. The UK tax system does not replace your US filing obligations, but with the correct foreign tax credits we ensure you do not pay tax twice.

US & UK Double taxation usually happens when residency, sourcing, or entity classification is misaligned. We solve this by preparing a coordinated US–UK tax strategy, applying treaty reliefs correctly, and ensuring both tax returns support each other.

Most do not. UK accountants generally do not deal with US worldwide taxation, PFIC rules, LLC elections, or IRS filing requirements. We specialise in both systems and work alongside your UK accountant to ensure everything is aligned.

It depends on your residency, where the income arises, and how the other country treats the entity. We assess your situation and US Company Tax structure so it is taxed correctly in both jurisdictions without accidental double taxation.

Yes. The IRS requires full reporting of foreign pensions, investment accounts, and assets — even when tax is paid in the UK. We explain exactly what needs to be disclosed and ensure the filings are correct and penalty-free.

Absolutely. We complete the W-8 BEN forms & W-8 BENE Forms for you, apply the right treaty articles, and ensure your US withholding tax drops from 30% to the treaty-reduced rate where applicable.

We review your past IRS and HMRC submissions, identify errors or mismatches, and correct them through amended filings. Our goal is to get you back to full compliance with the lowest possible financial impact.

Often yes. We advise whether you need an ITIN or EIN and support the entire application process as Certified Acceptance Agents, including identity verification without sending original passports to the IRS.

Yes. Many clients come via adviser referrals. We work directly with your professional team to provide cross-border clarity and ensure advice given in the UK aligns with IRS requirements.

Book a US & UK Expat Tax Diagnostic Call. We assess your residency, review your existing filings, identify risks, and outline the steps needed to create a coordinated US–UK tax strategy.