By using this site, you agree to the Privacy Policy and Terms of Use.
Accept

Indestata

  • Home
  • News
  • Personal Finance
    • Credit Cards
    • Loans
    • Banking
    • Retirement
    • Taxes
  • Debt
  • Homes
  • Business
  • More
    • Investing
    • Newsletter
Reading: Guide to U.K-U.S. Cross-Border Tax Planning
Share
Subscribe To Alerts
IndestataIndestata
Font ResizerAa
  • Personal Finance
  • Credit Cards
  • Loans
  • Investing
  • Business
  • Debt
  • Homes
Search
  • Home
  • News
  • Personal Finance
    • Credit Cards
    • Loans
    • Banking
    • Retirement
    • Taxes
  • Debt
  • Homes
  • Business
  • More
    • Investing
    • Newsletter
Follow US
Copyright © 2014-2023 Ruby Theme Ltd. All Rights Reserved.
Indestata > Personal Finance > Taxes > Guide to U.K-U.S. Cross-Border Tax Planning
Taxes

Guide to U.K-U.S. Cross-Border Tax Planning

TSP Staff By TSP Staff Last updated: July 2, 2025 11 Min Read
SHARE

U.K.-U.S. tax planning involves understanding how income, residency and asset ownership are taxed under both British and American law. Dual residents, expatriates and cross-border investors often face parallel filing obligations, with each country maintaining its own system for taxing worldwide income. While a bilateral tax treaty exists to help reduce the chance of double taxation, U.S. citizens and green card holders living in the U.K. still must comply with IRS reporting requirements.

Who Needs U.K.-U.S. Tax Planning?

U.K.-U.S. tax planning affects a broad range of individuals and families, particularly U.S. citizens residing in the U.K., British nationals with U.S. investments and dual citizens.

American citizens living abroad are subject to U.S. taxation on their global income regardless of where they reside, which can create overlapping obligations with His Majesty’s Revenue and Customs (HMRC). Similarly, British residents who own U.S. property or work for U.S.-based companies may owe U.S. tax on income tied to those assets or activities.

For instance, an American living in London who earns income from a U.K. employer must file a U.K. tax return. They must also report that same income on their U.S. tax return, potentially triggering foreign tax credits or exclusions. Likewise, a British citizen receiving dividends from a U.S. corporation may be subject to U.S. withholding tax and must report that income to HMRC. Without coordinated planning, it’s possible to overpay—or underreport—resulting in audits or penalties on either side of the Atlantic.

Understanding the U.K.-U.S. Tax Treaty

The U.K.-U.S. Income Tax Treaty, first signed in 2001 and supplemented by subsequent protocols, outlines how income is taxed when a taxpayer has ties to both countries. It allocates taxing rights over specific types of income and helps reduce or eliminate double taxation through provisions like foreign tax credits, exemptions and mutual agreement procedures.

The treaty specifies which country has primary taxing rights over employment income, business profits, dividends, interest and pensions. For example, salaries are generally taxed only in the country where the work is performed, unless the income is below a certain threshold and the worker is present for fewer than 183 days in the tax year. U.S. citizens, however, do not receive full treaty benefits if they are taxed on worldwide income by the IRS, although they can still access credits and exclusions.

The treaty also includes tiebreaker rules to determine tax residency when someone qualifies as a resident in both countries under their respective domestic laws. These rules look at factors such as the location of a permanent home, the country of closest personal and economic ties and habitual abode. If none of these factors are conclusive, nationality may determine the outcome, or tax authorities in both countries may resolve the case through mutual agreement.