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Americans Holding UK Assets: Why Form 8938 and 3520 Reporting Is Being Missed by Wealth Managers

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TAX • CROSS-BORDER • 2026 Summary: Many US citizens living in the UK are fully compliant with HMRC — but quietly non-compliant with the IRS. UK ISAs, UK trusts, UK pensions and even standard investment accounts can trigger US Forms 8938 and 3520 reporting. This is where otherwise well-advised clients get caught out. UK tax efficiency does not equal US compliance. Form 8938 and Form 3520 are commonly overlooked by non-US advisers. Penalties can arise even where no additional US tax is due. Context: Who This Applies To This applies to US advisers with American clients resident in the UK who hold local UK assets — ISAs, UK unit trusts, UK discretionary trusts, UK pensions, investment bonds, and UK property structures. The client often believes they are “fully compliant” because their UK accountant and UK wealth manager have structured everything tax-efficiently for HMRC. That is only half the story. The IRS does not care that an ISA is tax-free in Britain. Nor does it ignore...
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British Citizens Moving to the United States: A Corrected UK–US Tax & Residency Guide (2026 Update)

 Relocating from the UK to the United States involves synchronising two very different systems of tax, immigration status, and residency determination. This guide provides a corrected, fact-checked overview based on guidance from HMRC, IRS, USCIS, and U.S. state tax authorities as of late 2025. UK Residence: When Do You Stop Being Tax Resident? The UK uses the Statutory Residence Test (SRT) to determine tax residency. If you leave mid-tax year, you may qualify for split-year treatment . This means only part of your income is taxed in the UK, and you must report it via Self Assessment. UK rental income remains taxable in the UK after you move. Other UK-source income, such as interest or dividends, may be classified as  disregarded income  for non-residents and may not be subject to UK tax. US Immigration Status: What You Can and Cannot Do Your immigration status governs what you may lawfully do in the US—not the number of days present. Visitors under ESTA or B-1/B-2...
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The 2025 UK Remittance Overhaul: What Expats, Non-Doms and New Arrivals Must Know

TAX • PLANNING • 2025 Navigating the UK’s New FIG Regime: What Replaces the Remittance Basis in 2025 Summary: The UK’s long-standing remittance basis has effectively been replaced from 6 April 2025 by the Foreign Income and Gains (FIG) regime. New arrivals who have been non-UK resident for 10 years may now bring foreign income and gains to the UK tax-free for four years. Existing non-doms, however, face a very different landscape. The FIG regime unlocks tax-free remittances for new arrivers — but only if the 10-year non-residence test is met. Many HNW families misunderstand the transition rules and create avoidable UK tax exposure when moving funds. Planning early (before becoming UK resident) is critical. Timing and source-segregation still matter. Context: Who This Applies To This is written for internationally mobile families, founders, and HNW professionals relocating to the UK. Many are used to the old non-dom regime — the remittance basis — and a...
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Americans With UK Limited Companies: If You Don’t File Form 5471, Here’s What Happens

US • UK • CROSS-BORDER TAX Summary: Many Americans who set up a UK limited company are told they don’t need to file Form 5471 . That advice is dangerously wrong. The IRS treats most UK companies owned by US persons as Controlled Foreign Corporations (CFCs), triggering Form 5471, Subpart F exposure, and potential GILTI taxation , even when no money is distributed. Form 5471 applies far more often than Americans are told CFC status can create GILTI tax on retained UK profits Penalties apply even if no US tax was owed The Myth Americans Keep Hearing Some accountants claim a UK Limited Company “keeps tax offshore” or “is treated separately so the IRS doesn’t care.” That’s not just wrong, it’s financially dangerous. Under US tax law, Americans are taxed on worldwide income, and foreign corporations they control are subject to mandatory filing obligations. When Form 5471 Applies Form 5471 applies when a US person owns shares, voting rights, or control thresholds in a UK compan...
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UK Exit Tax Explained: How HMRC Taxes You When Leaving the UK and Becoming Non-Resident

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TAX • RESIDENCY • LEAVING THE UK Summary: Leaving the UK does not automatically end your UK tax exposure. HMRC continues to tax certain income even after departure. Many people wrongly assume that becoming non-resident means paying no UK tax, but the rules are stricter than expected. Split-year treatment does not exempt income earned before departure UK companies may still create UK dividend tax liabilities Rental income and UK situs assets remain taxable in the UK Who This Applies To This guidance applies to individuals who are permanently leaving the United Kingdom, have ended full-time UK residence, or plan to work and live overseas for the foreseeable future. It includes employees, contractors, directors, landlords, shareholders of UK companies, and people with retained property income or investments still situated in the UK. Understanding UK Exit Tax Rules Leaving the UK does not create a formal “exit tax” in name, but HMRC applies a series of ...
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Leaving or Returning to the UK? Understand Your Tax Status Before You Move

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  Summary: Moving abroad or coming back to the UK can trigger unexpected tax bills. This guide explains how HMRC decides your residence, what income remains taxable, and how to claim tax refunds when leaving the UK. Learn how the Statutory Residence Test (RDR3) determines your tax status Find out what income stays taxable under UK law after you leave Discover how to claim refunds and avoid HMRC penalties Context: Who This Applies To This guide is for anyone leaving or returning to the United Kingdom — especially landlords, company directors, and digital nomads. Whether you’re retiring abroad, working full-time overseas, or moving back after a few years away, your UK tax position changes the moment your residence status changes. Understanding the Rules The UK tax year runs from 6 April to 5 April . Your UK residence status is determined by HMRC’s Statutory Residence Test (RDR3) , introduced by Finance Act 2013 Schedule 45 . It looks at how many days you spend in the UK...
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Helping US Realtors Manage British Clients Buying US Real Estate: Tax, Legal & FIRPTA Guidance (2025 Edition)

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  TAX • CROSS-BORDER • 2025 Summary: British buyers of US property face dual-jurisdiction tax exposure — the IRS taxes the US sale, and HMRC taxes the worldwide gain. US Realtors need cross-border planning support to avoid FIRPTA withholding traps, double taxation, and legal liability risks. IRS requires 15% FIRPTA withholding on property sales by non-US persons Buying via an LLC or C-Corp helps shield personal wealth from lawsuits HMRC taxes foreign property income and gains — with treaty relief possible Context: Who This Applies To This guidance is for US-based Realtors representing British clients purchasing or selling US real estate. These clients are typically: UK investors diversifying into Florida, Texas, or Arizona rentals British expats relocating to the US for work or retirement Dual-citizens managing homes in both the UK and US Why Legal Structure Matters In the US, litigation is common. Realtors advising foreign buyers mus...
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