Become the Trusted Cross-Border Advisor for British Clients in the US (US–UK Tax Made Practical)


 

Reduce double taxation, stop PFIC surprises, and align UK pensions and US filings—without losing client control.

US CPAs, EAs, and fiduciary advisors want to keep British-origin clients—but UK pensions, ISAs, and rental income create timing and reporting traps that risk penalties and erode trust.

UK/US timing mismatches, PFIC filings, and new residence-based IHT rules are easy to misapply.

You worry about “missing something UK-specific” that costs clients money.

British clients deserve advice that respects both tax systems—without duplication.

Optimise Accountants works behind the scenes with US advisors. Led by Simon Misiewicz FCCA ATT EA MBA, we align HMRC and IRS positions so you lead with confidence.

Plan / Roadmap

  1. Discovery call (your client stays yours).

  2. Dual-jurisdiction map: income, timing, and treaty positions.

  3. Documentation pack: elections, forms, reconciliations.

  4. Quarterly check-ins; annual filing support.

Rules & What Changed (2025)

  • Remittance basis abolished; 4-year FIG regime from 6 Apr 2025. New arrivals (not UK-resident in prior 10 tax years) can claim 100% relief on eligible foreign income/gains for up to four years. GOV.UK+1

  • Residence-based IHT from 6 Apr 2025. Non-UK assets can fall within IHT if a resident for 10 of the last 20 tax years. GOV.UK+2GOV.UK+2

  • FEIE for 2025 = $130,000. (Form 2555). IRS

  • FBAR penalty ranges (2025). Non-wilful up to $16,536 per violation; wilful, the greater of $165,353 or 50% of the account balance. Hughes Noff Tax Law+1

Three real-world examples

  1. UK pension lump sum + Article 17: Client assumed the 25% UK tax-free lump sum was US-tax free. With the correct Article 17 approach and timing across tax years, we reduced the effective US rate and avoided double inclusion. GOV.UK

  2. ISA → PFIC: £750k across UK OEICs triggered Form 8621. We prepared for six years, used streamlined compliance, and moved to US-domiciled ETFs going forward—eliminating PFIC going ahead.

Failure vs Success

Ignore: unnecessary US tax on UK pensions; PFIC penalties; duplicated income; IHT exposure across both systems.

Act: aligned filings, accurate FTCs, PFIC-free structures, documented treaty positions.

Action List

  • Map pensions/investments to treaty Articles 17 & 24.

  • Screen UK funds for PFIC; prefer US-domiciled ETFs/direct equities.

  • Reconcile income each April & December.

  • Confirm FBAR (FinCEN 114) and Form 8938 thresholds every year.

  • For movers to the UK: assess FIG eligibility and residence-based IHT exposure.

Learn more and book a strategy call: https://www.optimiseaccountants.co.uk
Reference article: https://internationaltaxesadvice.com/us-uk-tax-advice-for-american-wealth-managers-with-british-clients/
Watch: https://www.youtube.com/embed/x3sGUKf1DeI?si=Zv3BGDqSVr-IdO49

#USUKTax, #CrossBorderTax, #PFIC, #Pensions, #EstatePlanning


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