US & UK Tax Articles

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...

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 ...

  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...

  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...

Imagine waking up one day to find that a large portion of your wealth has been shaved off due to sudden changes in  UK tax policies .  The  Labour Party  has just introduced reforms that could drastically increase  Capital Gains Tax , raise  corporation tax , and, worst of all, impose a brand-new  wealth tax . You could be hit hard if you’re a high-net-worth individual or an executive with significant assets. Your retirement plans, investments, and business may no longer be as secure as you thought. These new  UK tax changes  could leave you feeling cornered, with limited options to preserve your hard-earned wealth. But what if you knew how to protect yourself before it’s too late? Now, picture a different scenario: You're an executive considering moving from the UK to Spain. Spain’s tax system might seem daunting at first, but compared to the new  UK tax regime , it could be a saving grace. Although Spain has high personal income taxes,...