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HorizonUK Tax Solutions

What UK taxes apply when moving from the USA?

Answered by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 9 August 2026. Last reviewed 9 August 2026.

The short answer

You pay UK tax on UK income from day one, and on worldwide income and gains once you are UK resident under the Statutory Residence Test, though most Americans qualify for the four-year FIG regime, which can relieve US income and gains from UK tax for the first four resident years. What does not change is the American side: the US taxes its citizens and green card holders wherever they live, so you keep filing a Form 1040 alongside UK Self Assessment. The two returns must be prepared with each other in view, because a FIG claim removes the UK tax and with it any UK credit against the US bill on that income.

  • UK residence is decided by the Statutory Residence Test: 183 or more UK days makes you automatically resident, and split-year treatment usually taxes you as a resident only from your arrival date.
  • Anyone who has never been UK resident meets the 10-year non-residence test automatically, so most arriving Americans can claim the FIG regime for up to four years.
  • Each FIG claim year costs the £12,570 personal allowance and the CGT annual exempt amount, and the relief is UK-only: the US still taxes the same income.
  • On the US return the foreign tax credit usually beats the Foreign Earned Income Exclusion ($132,900 for 2026) because UK rates are generally higher, and the FEIE election persists until revoked.
  • US information reporting follows you: FBAR and FATCA pick up your new UK bank accounts, pensions and investments once thresholds are met.

The UK side: residence, split year and the FIG window

UK residence has nothing to do with your visa; it is decided mechanically by the Statutory Residence Test across the tax year running 6 April to 5 April. Arrive mid-year and split-year treatment usually divides the year so you are taxed as a resident only from arrival, though your calendar-year Form 1040 keeps running underneath. Most Americans qualify for the FIG regime because anyone who has never been UK resident meets the 10-year non-residence test automatically: a claim on the SA109 pages gives full UK relief on qualifying foreign income and gains for up to four years, at the cost of the £12,570 personal allowance and the CGT annual exempt amount each claim year. Arrival timing matters: a split year still burns a full year of the four-year clock, so landing shortly after 6 April usually works best.

The US side does not switch off

The United States taxes on citizenship, not residence, so citizens and green card holders keep filing worldwide-income returns from the UK, and FBAR and FATCA reporting picks up new UK accounts once thresholds are met. On the US return, the Foreign Earned Income Exclusion shelters up to $132,900 of foreign earned income for 2026, but for most Americans employed in the UK the foreign tax credit works out better because UK rates are generally higher, and the FEIE election stays in effect until revoked. The critical interaction: income sheltered by a FIG claim carries no UK tax to credit, so the US tax on it stands, which makes every FIG claim a two-country calculation. Watch the account traps too: UK funds and ISA holdings are generally PFICs for US purposes, with punitive treatment, so review structures before you open anything.

Two calendars, one sequence

You will run two filing clocks: UK Self Assessment online by 31 January after the 5 April year end, with the SA109 needing commercial software or an adviser, and the US return due 15 April with an automatic extension to 15 June for Americans abroad. The rhythm that works is UK first, US second, so the UK figures feed the foreign tax credit workings on the calendar-year US return; the US-UK treaty then stops the same income being fully taxed twice. Horizon UK Tax Solutions runs the UK side on fixed fees agreed upfront, with expat returns from £550 and complex cross-border cases from £750, while US filings are handled by our US partners (Enrolled Agents and CPAs), whom we coordinate for you; book a free clarity call at /book to plan the move before the SRT clock starts.

This is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

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