Navigating Dual Taxes: A Guide for U.S. Citizens Living in the U.K.

 

If you’re a U.S. citizen living in the U.K., you may be subject to dual taxation, meaning you must pay taxes in both countries. It can be a daunting and confusing process, but with the right guidance, it can be manageable. Continue reading to learn more about navigating taxes as a U.S. citizen living in the U.K.

Understanding Dual Taxation

The U.S. and the U.K. have different tax systems, and it’s essential to understand how they work to avoid issues with dual taxation. For example, the U.S. taxes most citizens on their worldwide income, regardless of where they live. On the other hand, the U.K. taxes some of its residents based on their income generated within the country. 

So, as a U.S. citizen living in the U.K., you are likely subject to U.S. and U.K. taxes. However, the two countries have a double taxation agreement (DTA) to ensure taxpayers are not double taxed on the same income.

Determining Your Tax Residency Status

Before navigating dual taxation, you need to determine your tax residency status. It will determine which country has the right to tax your income.

For U.S. citizens living in the U.K., the substantial presence test, which looks at the number of days you have been physically present in the U.K. over three years, determines your tax residency status. If you meet the test criteria, you are considered a U.K. tax resident and must pay taxes in the U.K. on your worldwide income. Conversely, if you do not meet the test, you are considered a non-resident and only need to pay U.K. taxes on income earned in the U.K.

Filing Your US Tax Return

As a U.S. citizen, you’re required to file a tax return with the Internal Revenue Service (IRS) regardless of where you live. You may also need to pay U.S. taxes if you earn over a certain threshold. Therefore, it’s essential to file your U.S. tax return by the deadline, which is typically April 15, to avoid penalties. If you need more time to file, you can request an extension.

Understanding U.K. Taxation

In the U.K., you’re subject to tax on your worldwide income if you’re a resident. So, you’ll need to register for a National Insurance number and file a tax return with HM Revenue & Customs (HMRC) each year. The tax year in the U.K. runs from April 6 to April 5 the following year. So, you’ll need to file your tax return by January 31, following the end of the tax year.

Taking Advantage of the Tax Treaty

The U.S.-U.K. tax treaty helps prevent double taxation by allowing for foreign tax credits. These credits will enable you to reduce your U.S. tax liability for taxes paid to the U.K. These include the foreign tax credit, which allows you to offset U.S. taxes with foreign taxes paid, and the foreign earned income exclusion, which allows you to exclude a portion of your foreign income from U.S. taxation. You can claim the credit by filing Form 1116 with your U.S. tax return.

The treaty also provides relief for certain types of income. For example, if you are a U.S. citizen living in the U.K. and sell your primary residence in the U.K., you may be exempt from U.K. capital gains tax under the treaty.

Keeping Accurate Records

When it comes to taxes, keeping accurate records is essential, especially for U.S. citizens living in the U.K. subject to dual taxation. You will need to keep records of your income and taxes paid in both countries to ensure that you are paying the appropriate amount of taxes.

Seeking Professional Advice

Navigating dual taxation can be complex, so it’s wise to seek the help of a tax professional. A qualified tax advisor can help you determine your tax obligations, claim applicable credits and exemptions, and ensure U.S. and U.K. laws compliance. Charitable investments can further complicate taxes, particularly with international donations and grantmaking. Again, getting professional guidance in these cases is strongly advised.


TrustBridge Global member, International Generosity Foundation works with U.S. and U.K. donors to address their unique needs and offers giving solutions designed to maximize the benefits of charitable giving. All giving solutions ensure compliance with U.S. and U.K. tax laws, making global giving radically easier, faster, and less expensive. To learn more, visit https://www.internationalgenerosity.com/igftransatlantic

 
Jim Rich