Residency & Treaty

US-UK treaty planning

Residence tie-breaker, pension sourcing, capital gains, and double-tax relief under the US-UK treaty.

Residency & Treaty
Overview

Why this filing matters

Residence tie-breaker, pension sourcing, capital gains, and double-tax relief under the US-UK treaty.

Note — Residence & double tax relief.

Who this is for

  • Dual residents
  • Clients with cross-border income sources

What you get

  • Treaty residence analysis
  • Article-by-article relief review
  • Form 8833 disclosures
Our approach

Built for the cross-border edge cases.

Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.

We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.

  • Position memo on every meaningful election, with the reasoning written down for the next return
  • Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
  • Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Mapping residency days across two tax systems
Our process

How we handle your us-uk treaty planning

Four steps from first call to filed return. Fixed fee confirmed before any work begins.

  1. 01

    Intake

    30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.

  2. 02

    Review

    We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.

  3. 03

    Prepare

    Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

  4. 04

    File

    E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.

Pricing

Fixed fees — no surprises

Treaty planning: £400–£800 + VAT depending on scope (single-article position vs comprehensive review). Form 8833 preparation is included.

FAQs

Common questions about US-UK treaty planning

Does the treaty override US citizenship-based taxation?
Very narrowly. US persons generally remain subject to US tax on worldwide income even when treaty-resident in the UK. Specific articles (pensions, government service, students) carve out real relief, but the saving clause preserves most US taxing rights.
Can the treaty reduce my US state tax?
No — treaties bind the US federal government, not US states. State residency and taxation operate independently. California and New York are particularly known for ignoring treaty arguments.
Does the treaty cover US Social Security?
Yes — Article 17(3) generally gives the residence country exclusive taxing rights over social security benefits. If you're UK-resident receiving US Social Security, the UK has primary taxing rights.
How do I claim treaty benefits in practice?
Typically via Form 8833 disclosure with your tax return. For certain income at source (dividends, interest, royalties), a W-8BEN to the payor reduces withholding up front. We coordinate both routes.

Ready to get this filed?

Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.