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Topic: US Citizen and US Greencard Holder Moving to UK Tax/Stock Question  (Read 1209 times)

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Hello!

My husband, son and I are trying to figure out if we should move to England. My husband has an offer but we are very concerned about Taxes and Stock Capital Gains and savings.

He is a US citizen and I am a British Citizen with a green card in the US. Son is dual.

-If we have over $10,000 in saving in the US is that okay? Would the UK tax us? Would the US tax us?
-What would you do with your 401K ?
-What happens if we start a retirement rment plan in the UK, does the US/UK tax us?
-My husband is very involved with the stock market in the US. Will he be able to invest in the US while living in the UK? how would that be taxed be the US or UK?
-How do the taxes work for people making over £110,000 work in the US? Is that house hold income or is there a different threshold for couples both working?
-What happens if we have over $10,000 in savings in the UK? Are we taxed on this in the US or the UK?

Please let me know if you have any finance advisers you would recommend that specialize in Expats or tax consultants that we should talk to. My husband would need to accept the offer this week so really want to get a basic understand so we can make the best choice.

Thank you!


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Re: US Citizen and US Greencard Holder Moving to UK Tax/Stock Question
« Reply #1 on: February 24, 2021, 12:51:26 PM »
I see no one has responded and you are pressed for time. I don't know the answers to all your questions but hopefully I can confirm what you may have already found out elsewhere.

What is unclear is the £110,000. Is that for one person, or is it the household income for 2 people? HMRC do not have a "Joint" filling option. Each person is taxed individually. Research HMRC tax brackets (20%, 40%, and 45% as of today!). £110,000 is nearing the top bracket which carries some reductions - like personal allowance.

HMRC taxes on worldwide income (the "Arising Basis") so if resident in the UK for tax purposes, income from anywhere in the world is taxed by HMRC (baring Treaty exceptions!). There is a second option, the "Remittance Basis", which you may want to explore, but it is usually for high net worth individuals with residences in multiple countries.

H.......... we are very concerned about Taxes and Stock Capital Gains and savings.

He is a US citizen and I am a British Citizen with a green card in the US. Son is dual.
        Will you keep or surrender your Green Card? This could have a substantial bearing on your situation.

-If we have over $10,000 in saving in the US is that okay?
     Yes, no problem.

Would the UK tax us?
     Yes, if on the arising basis.

Would the US tax us?
     Yes. Unlike the UK, the IRS will tax all interest, including the UK tax free amounts.
 
-What would you do with your 401K ?
     I have no idea, but it should stay in the US. I believe the option to self manage funds will cease, but this is not for me to
     answer. Perhaps others with experience can reply
.


-What happens if we start a retirement rment plan in the UK, does the US/UK tax us?
     Not a problem. Upon retirement (if a normal Employer plan) the UK will tax the pension. and so will the IRS. You would use
     Foreign Tax Credits (FTC) to offset the IRS liability.

     Research: Basis, UK employer contributions. If not an employer plan - IRS form 3520.

-My husband is very involved with the stock market in the US. Will he be able to invest in the US while living in the UK?
    Yes, BUT WITH MAJOR CAVEATS. Not for me to answer, perhaps others?
    Research: HMRC reporting funds list.
                      Vanguard.
                      Are they individual or mutual fund shares?
                      PFIC (IRS), a very punitive tax situation if the shares are mutual funds held, or from a broker, outside the US.

hopefully  how would that be taxed be the US or UK?
    Both the US and UK will tax the cap gains. The UK rate and method of taxation is different from the US, but either UK or US liability could be offset. For someone else to answer.

-How do the taxes work for people making over £110,000 work in the US?
    You would definitely want to use the FTC (form 1116). Both the UK and US will tax it (with exceptions for UK personal allowances and US standard
     deduct., etc.) IRS liability is offset (for the most part, but not always) by 1116.

  Is that house hold income or is there a different threshold for couples both working?
    HMRC only taxes on an individual basis.
 
-What happens if we have over $10,000 in savings in the UK? Are we taxed on this in the US or the UK?
    Both, but might be offset in the US. There are some amounts that are tax free in the UK, depending on income, and options
     for additional tax free interest in the UK (cash ISA), but UK tax free income is taxed by the IRS.
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Please let me know if you have any finance advisers you would recommend that specialize in Expats or tax consultants that we should talk to. My husband would need to accept the offer this week so really want to get a basic understand so we can make the best choice.

     All of your situation is very normal. The only potential problem would be if any your husband's share trading is outside
     the US. This needs thorough research. PFICs!!!!!


« Last Edit: February 24, 2021, 12:58:42 PM by theOAP »


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Re: US Citizen and US Greencard Holder Moving to UK Tax/Stock Question
« Reply #2 on: February 24, 2021, 01:30:29 PM »
On the 401k question, what my wife and I did, and our son when he moved over, was to roll our 401ks into IRAs with a brokerage that allowed us to manage the accounts from the UK. The rollover is a tax free event but you are best doing this before you move. In the case of our son he only had 2 weeks after quitting work in the US to do this but the process was underway by the time he left the USA. The rollover completed a week or so after he had arrived in England. Like us he has full access to it online from here.

We converted our taxable mutual funds into HMRC reporting ETF funds and removed my name from them as the UK taxes on an individual basis and my wife currently has no other income so the dividends and capital gains use her tax free allowances so are effectively not taxed in the UK. Again they are in a brokerage account that we manage from England and do sales and purchases from. We kept a US bank linked to the brokerage for transfer to and from, and we move money to the UK from that US bank using Transferwise. (Most of our income is from my US private pensions)
Dual USC/UKC living in the UK since May 2016


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Re: US Citizen and US Greencard Holder Moving to UK Tax/Stock Question
« Reply #3 on: February 24, 2021, 04:04:44 PM »
Thank you so much for everyone's help!! Hopefully all goes to plan and we move!


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