Two tax systems

Tax for Brits in the US

Tax is the part of moving to America that catches out even careful planners. This page explains in plain English how the UK and US systems fit together, when each country can tax you, and the forms Brits in the US meet most often. It is general information only, not tax advice.

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Q. Will I be taxed in both the UK and the US if I move to America?

Both countries can have a claim, but the systems are built so the same income is not normally taxed in full twice. Once you are a US tax resident, the US taxes your worldwide income. Once you are non-UK resident, the UK generally taxes only your UK income, such as rent from a UK property. Where both tax the same income, the US foreign tax credit and the US-UK tax treaty are there to stop it being taxed in full twice.

Seek professional advice on anything like this. The Directory lists specialists.

Q. When do I become a US tax resident as a Brit moving to the USA?

The US has two main tests. Meet either and you are a resident for US tax purposes.

  • Green card test: you were a lawful permanent resident at any time in the calendar year.
  • Substantial presence test: you were in the US on at least 31 days this year, and 183 days over three years, counting all of this year's days, one third of last year's and one sixth of the year before's.

Some days do not count, for example for certain students, teachers and trainees on particular visas. The year you arrive is often a dual-status year, non-resident for part of it and resident for the rest, with its own filing rules. IRS Publication 519 sets out the full rules.

Your visa does not decide it Being on a temporary work visa does not stop you becoming a US tax resident. The day count does.

Q. Do I still need to file a UK Self Assessment after moving to the US?

It depends on what you leave behind. Moving does not by itself close your UK tax affairs, and non-residents still pay UK tax on UK income, such as rent from a UK property. If HMRC asks you to send a return, you must, even if you think no tax is due.

Seek professional advice on anything like this. The Directory lists specialists.

Q. Do I pay UK tax on rental income if I live in America?

Usually in both countries. Rent from UK property stays taxable in the UK wherever you live, and non-resident landlords normally join the Non-resident Landlord Scheme so the letting agent or tenant does not have to deduct tax at source. The same income also goes on your US return, with the UK-US tax treaty and foreign tax credits deciding who taxes what.

Seek professional advice on anything like this. The Directory lists specialists.

Q. Do I pay capital gains tax if I sell my UK house after moving to the USA?

Possibly in both countries. The UK can tax non-residents on gains from UK homes, and the US taxes its residents on worldwide gains, so the sale can appear on both returns, with credits available to stop the same gain being taxed in full twice. Non-residents must report a UK property sale to HMRC within 60 days of completion, even when no tax is due.

Seek professional advice on anything like this. The Directory lists specialists.

Q. What happens if I haven't been reporting my UK accounts to the IRS?

You are far from alone. Many Brits in America had no idea these reports existed. Penalties do exist for missed FBARs and Form 8938s, but the IRS also has formal routes for people who come forward and whose failures were not wilful.

Seek professional advice on anything like this. The Directory lists specialists.

Q. What is an FBAR, and do I need to file one?

The FBAR is an annual report of foreign bank and financial accounts. It is required once the combined value of your non-US accounts tops $10,000 at any point in the year. That is the total across every account, and a dormant UK current account still counts. FATCA reporting on Form 8938 has higher thresholds but covers a wider range of assets. Both are separate from your tax return, and both carry significant penalties.

Seek professional advice on anything like this. The Directory lists specialists.

Q. What happens to my ISA and UK investments when I move to the US?

You can keep an ISA after you leave, but once you are non-UK resident you cannot pay new money in. The US does not recognise the ISA wrapper, so income and gains inside it are generally taxable in the US. Many UK funds also come under complex US rules (known as PFIC rules), and some UK platforms restrict accounts for US residents.

Seek professional advice on anything like this. The Directory lists specialists.


When to get professional help

These answers explain how the rules work. They cannot tell you how they apply to your own income, accounts and plans. For that, a cross-border tax professional who understands both systems is the right person. The Directory lists specialists.

Figures and rules checked September 2026 against IRS, HMRC and GOV.UK pages. Tax thresholds change each year, so check the official page linked in each answer.