US and UK Tax Filing for People Moving Between Countries
Moving between the US and the UK — whether you're a US national moving to the UK, a UK national moving to the US, or moving back and forth — creates a complex dual-jurisdiction tax situation. Both the IRS and HMRC will have claims on your income, the tax year end dates don't align, and the US-UK tax treaty requires careful application. We have specialist expertise in coordinating US and UK tax returns for people moving between both countries.
Get started with your filingWho this is for
- ✓ US citizens relocating to the UK and establishing UK tax residency
- ✓ UK nationals who moved to the US and are now leaving again
- ✓ Those who spent significant time in both countries in the same year
- ✓ Dual US-UK citizens managing permanent obligations to both tax systems
- ✓ Anyone who needs to apply the US-UK treaty tie-breaker provisions
What this filing may involve
Every situation is different. The forms below commonly apply — your specific filing may vary.
- 1 US Form 1040 — full-year US filing with FEIE and FTC as applicable
- 2 UK SA100 with SA109 and split-year treatment claim
- 3 US-UK Treaty tie-breaker residence determination
- 4 Form 1116 — US FTC for UK taxes paid in the transition year
- 5 FinCEN Form 114 (FBAR) — for accounts in both jurisdictions
Documents usually needed
- 📄 Travel records showing exact dates in the US and UK
- 📄 Evidence of residency establishment in the new country
- 📄 Income records for both the US and UK portions of the year
- 📄 Bank account statements in both countries
- 📄 P60 or P45 (UK) and W-2 (US) as applicable
How Nomadic.Tax works
AI-assisted preparation with licensed professional review — every time.
We apply both the US FEIE rules and the UK Statutory Residence Test to map your obligations
Split-year treatment on the UK return and partial-year FEIE election on the US return are coordinated
The US-UK treaty is applied where it reduces double taxation
Separate licensed professionals for US (CPA) and UK (tax specialist) review each return before filing
When human review matters
- ⓘ The US and UK tax years don't align — coordination between April 5 UK year-end and December 31 US year-end is critical
- ⓘ US citizens cannot fully escape IRS obligations by becoming UK resident — both systems continue to apply
- ⓘ The treaty tie-breaker provision determines which country taxes you as a resident in case of dual residency
Deeper reading on NomadIcTax.org, our educational resource site
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- dual US-UK citizen, London, UK
Relevant plans
Choose the package that best fits your situation, or view all plans.
- ✓ Everything in Standard
- ✓ Schedule C & SE for self-employment
- ✓ Multiple income sources and currencies
- ✓ Everything in Premier
- ✓ Foreign Earned Income Exclusion (Form 2555)
- ✓ Foreign Tax Credit (Form 1116)
- ✓ FBAR filing (FinCEN 114) included
- ✓ Statutory Residence Test & split-year review
- ✓ Non-resident landlord and UK property income
- ✓ UK company salary/dividends for non-residents
Frequently asked questions about US and UK Tax Filing for People Moving Between Countries
How do I handle moving from the US to the UK mid-year for tax purposes?
On the US side, you file Form 1040 for the full year, with FEIE applying to income earned after your move (via the chosen 12-month period). On the UK side, you file SA100 with SA109 and claim split-year treatment, which divides the year into your non-UK part (before arrival) and UK part (after arrival).
What is the US-UK tax treaty and how does it help?
The US-UK Comprehensive Income Tax Convention provides relief from double taxation in specific situations — for example, determining which country has primary taxing rights on pension income, business profits, and capital gains. However, US citizens can't use the treaty to eliminate US tax obligations entirely due to the 'savings clause'.
Can you file both my US and UK returns?
Yes. We have both licensed US CPAs and UK Self Assessment specialists. For clients with obligations to both tax systems, we coordinate both returns to ensure consistency in income allocation and avoid double taxation.