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Topic: UK Citizen moving to the US  (Read 1644 times)

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UK Citizen moving to the US
« on: November 13, 2023, 02:11:27 PM »
Can anyone offer some broad advice?

We are moving to the US next year (Arizona). My wife and son are American (and UK citizens) and we all live here in the UK. I'm filing for a green card from here. 

If I am to work remote from the US for my current UK company (small co and they are fine with it), I'm assuming I will pay US taxes on my income and not UK?

Also, we are going to rent our UK home out, will the rental income be subject to US taxes and not UK?



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Re: UK Citizen moving to the US
« Reply #1 on: November 13, 2023, 03:37:16 PM »
I don't know the answers but am interested in the replies.

When I moved to the US 36 years ago my company switched me from their UK payroll to their US payroll, plus they provided a tax accountant to handle the taxes.  I do recall that as a non-resident in the UK I was not subject to any/most UK taxes but the US taxed me on my worldwide income including interest on my UK savings accounts. I filled a form in with my UK banks which stated I was not a UK resident so they paid the interest gross. (Up until a few years ago interest was paid net of taxes by banks).

I know that I had to prepare a profit and loss account each year on my UK house rental but don't recall whether the IRS or HMRC taxed the profit. If it was both then foreign tax credits would be used to offset the taxes.

Useful article on the US taxing foreign rental property
https://www.greenbacktaxservices.com/knowledge-center/report-rental-income-foreign-property/#:~:text=For%20the%20most%20part%2C%20foreign,with%20a%20US%20rental%20property.

Quote
For the most part, foreign rental property is treated the same as a domestic rental property. This means that as an expat property owner, you will generally report your foreign property rental income and expenses just like you would with a US rental property. There are only a few distinctions, such as the foreign tax credits available for expat property owners and the changes to depreciation rules.

Here is the US-UK double taxation agreement

https://assets.publishing.service.gov.uk/media/5a81972ce5274a2e8ab54ce7/usa-consolidated_-_in_force.pdf

https://home.treasury.gov/system/files/131/Treaty-UK-Protocol-TE-7-22-2002.pdf
« Last Edit: November 13, 2023, 03:46:25 PM by durhamlad »
Dual USC/UKC living in the UK since May 2016


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Re: UK Citizen moving to the US
« Reply #2 on: November 13, 2023, 09:26:01 PM »
It’s going to boil down to SRT. If you work outside the U.K. full time then you’re a none U.K. resident from day one. As you’re under PAYE, even though outside the U.K., I’d suspect HMRC will fully tax you and so will the IRS. You’d use FTC against your IRS liability though. Best to get on to US payroll from day one, as you’d want the all important medical. If you can do this, it’ll make it easier to register as a none resident landlord.


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Re: UK Citizen moving to the US
« Reply #3 on: November 16, 2023, 03:24:16 PM »
AS you'll be living and working in the US (btw I spent 6 years in Arizona - a great and surprisingly diverse state - if you can stand the summer heat!) you'll be subject to US income taxes. Leaving the UK and staying out for a full tax year will mean that your earned income will not be subject to UK income tax - depending on timing of your exit you may even get a refund from HMRC as you get a full year's personal allowance in the year of departure.

In terms of your rental income, you should read HMRC advice here: https://www.gov.uk/tax-uk-income-live-abroad/rent

Fluctuating Exchange rates can play havoc with rental income and capital gains on sale - something to be aware of.

Although retirement may seem a way off for you (I'm guessing here) , you should research the US Social Security system - many on this forum (myself included) benefit from having paid into both the UK & US systems - it's a benefit becasue we now get a UK state pension/US Social Security retirement benefit.


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