Choosing an Advisor
US-UK Tax Accountants: What CPA, EA, CTA and ACCA Actually Mean for Your Returns
No single qualification covers both US and UK tax. This guide explains what CPA, Enrolled Agent, CTA, ATT, ACCA and ICAEW each cover, what they do not, and the questions to ask before you hire anyone.
Short answer
No single qualification covers both US and UK tax. On the US side, Enrolled Agents (EAs) are licensed by the IRS specifically for tax, and CPAs are licensed by US states for accounting more broadly. On the UK side, the Chartered Tax Adviser (CTA) and Association of Taxation Technicians (ATT) qualifications are tax-specific, while ACCA and ICAEW are wider accountancy bodies. Someone holding a US and a UK credential is uncommon. What matters most is that the people preparing each country's return are qualified in that country, and that the two returns are prepared together so they agree.
Key points
- Enrolled Agent (EA): an IRS credential earned by passing a three-part exam on US tax, or through IRS experience. Ongoing education is required.
- CPA: a state licence covering audit, accounting and tax. Many CPAs specialise in areas other than tax.
- CTA: the UK's senior tax qualification, awarded by the Chartered Institute of Taxation.
- ATT: a UK tax technician qualification, often a step towards CTA.
- ACCA and ICAEW: UK chartered accountancy bodies whose members often work in tax, with professional conduct rules.
- In the UK, giving tax advice is not a regulated activity. Anyone can call themselves a tax adviser, so credentials and professional body membership are worth checking.
Why the combination matters for Americans in the UK
A US citizen in Britain files in both countries. The returns depend on each other. UK tax paid becomes a foreign tax credit on the US return. Treaty positions taken on one return have to be mirrored on the other. Currency conversions and tax year differences need to line up too. The UK tax year ends on 5 April, the US year on 31 December. A US preparer with no UK knowledge can miss a UK pension's treaty status. A UK accountant with no US training can recommend an ISA that becomes a PFIC headache. The value of a cross-border firm is less about any one letter after a name and more about the two sides being checked against each other.
What each credential does and does not tell you
Enrolled Agent. Shows tested knowledge of US federal tax and continuing education. EAs have unlimited rights to represent taxpayers before the IRS, but whether a particular firm offers representation is a separate question. Some cross-border firms, including TaxStone, prepare returns and corrections and leave correspondence with the IRS to the client.
CPA. Shows a broad accounting education and a state licence. A CPA who works mainly in audit may know less US expat tax than an EA who files only for Americans abroad. Ask what share of their work is international individual tax.
CTA and ATT. Show tested UK tax knowledge. A CTA is a strong signal for complex UK matters such as residence, domicile changes, trusts and capital gains.
ACCA and ICAEW. Show a full accountancy qualification and membership of a body with ethics rules and complaints procedures. Many UK practitioners who prepare Self Assessment returns hold one of these.
Questions worth asking any firm
- Who prepares my US return, who prepares my UK return, and what are their qualifications?
- Are both returns prepared together, with the foreign tax credit and treaty positions reconciled?
- How many US citizens in the UK do you file for each year?
- Do you handle FBARs, Form 8938 and forms for UK funds, pensions and companies?
- What is not included? For example, do you deal with the tax authorities on my behalf, or do I?
- Is the fee fixed before work starts, and what would change it?
How TaxStone is set up
TaxStone is a tax firm only. We prepare US and UK returns and provide tax advice for Americans connected to the UK. Our US work is led by Enrolled Agents, and our UK work is prepared by ACCA-qualified accountants. Each engagement starts with full identity checks and a signed engagement letter setting out exactly what is included. We work by email so every figure and assumption is written down. We do not represent clients before the IRS or HMRC, and we do not give investment advice. You can read more on our About and How we work pages.
Sources
- IRS, "Enrolled Agent information" and Circular 230
- IRS, "Understanding tax return preparer credentials and qualifications"
- NASBA and state boards of accountancy, CPA licensing
- Chartered Institute of Taxation (CTA) and Association of Taxation Technicians (ATT)
- ACCA and ICAEW, membership and professional conduct
- GOV.UK, "Standard for agents" (HMRC's expectations of tax agents)