US & UK Tax Articles

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...

  Watch the video Summary American clients in the UK face a maze of HMRC/IRS rules. HMRC’s March 2024 update to INTM163160 tightened treatment of pension lump sums for US residents. PFIC rules make ISAs, OEICs and VCTs hazardous. This post outlines practical steps for UK wealth managers to reduce tax drag, avoid penalties, and safeguard client outcomes. Who this applies to UK wealth managers, IFAs, and accountants advising US citizens/green card holders in the UK, UK nationals moving to or investing in the US, and family offices coordinating dual filings. Why this matters now HMRC’s compliance yield rose 22.7% to £4.1bn in 2023–24, and offshore enforcement has recovered £3.2bn+ since 2010. FATCA/CRS data sharing means US/UK authorities already see the accounts—mistakes are rarely invisible. Key cross-border friction points Pensions and INTM163160 (Mar 2024): Clarifies how lump-sum pension benefits can be taxed when the recipient is US-resident. PFIC exposure: Most UK fund...