The Journal

Tax & Accounting, Clearly Explained

Practical insight for founders, expats and businesses across the US, UK and UAE.

Moving a UK pension to the United States: QROPS transfers, the overseas transfer charge and US-UK treaty tax
US-UK
Can You Move a UK Pension to the US? QROPS, the Overseas Transfer Charge and Why Staying Put Often Wins
A UK pension can only go overseas to a QROPS, a 25% charge may apply, and US plans are rarely a clean destination. Often the answer is to leave it.
US citizen paying themselves from a UK limited company: salary, dividends, CFC rules and US tax
US-UK
Paying Yourself From Your UK Company as a US Citizen: Why Salary and Dividends Work Differently
The UK small-salary-plus-dividends mix is built for UK tax. For a US citizen, CFC rules and credit limits can make it the costlier choice.
Stamp Duty Land Tax for an American buying a home in England: higher rates, non-resident surcharge and US basis
US-UK
Stamp Duty When an American Buys a Home in England: The Non-Resident Surcharge and the Other Layers
A US home can trigger higher rates, a day count can trigger the non-resident surcharge, and the US treats SDLT as basis, not a deduction.
Lifetime ISA for a US citizen in the UK: the 25% government bonus, PFIC exposure, FBAR and the withdrawal charge
US-UK
The Lifetime ISA for US Citizens in the UK: Why the 25% Bonus Is Not the Whole Story
The Lifetime ISA's bonus and tax-free growth are UK-only. For a US citizen, the account is taxable, reportable and costly to leave behind.
Pre-arrival US-UK tax planning for Americans moving to the UK: residence start date, FIG regime and inheritance tax
US-UK
Pre-Arrival Tax Planning: What a Wealthy American Should Settle Before Moving to the UK
UK residence switches on worldwide taxation from a date the statute fixes. The months before you land are the only window in which several choices still exist.
Winding up a UK company as a US person: members' voluntary liquidation, striking off and the US tax on the exit
US-UK
Winding Up a UK Company When You Are a US Person: MVL, Striking Off and the Rules Nobody Mentions
Closing a solvent UK company converts retained profit into capital. For a US shareholder it is a second taxable event, with anti-avoidance rules on both sides.
UK company share buyback and US shareholders: HMRC capital treatment, clearance and IRS redemption rules
US-UK
UK Share Buybacks and US Shareholders: When One Cheque Is Capital in London and a Dividend in Washington
A UK purchase of own shares can be capital for HMRC and a dividend for the IRS. Two systems, two tests, one payment - and a broken foreign tax credit.
UK settlement agreement and termination payment tax for a US citizen: the £30,000 exemption, PENP and US tax
US-UK
UK Settlement Agreements and the US Person: Why the Tax-Free £30,000 Is Not Tax-Free
The UK exempts part of a termination payment. The US does not mirror it, and with no UK tax behind that slice there is nothing to credit.
Non-executive director fees for a US person on a UK board: PAYE, National Insurance and US self-employment tax
US-UK
Non-Executive Director Fees and the US Person: Why a UK Board Seat Is Messier Than It Looks
The UK taxes a directorship as an office, through PAYE and National Insurance. The US treats the same fee as self-employment income. Both can be right.
UK residential property held through a company: ATED, US Form 5471 reporting and de-enveloping for American owners
US-UK
UK Residential Property in a Company: ATED, and What It Means for a US Owner
An annual UK charge on enveloped homes - and for an American owner, a foreign corporation the IRS wants reported. What the structure now costs on both sides.
US citizen selling a UK company to an Employee Ownership Trust: UK CGT relief and US capital gains tax
US-UK
Selling to an Employee Ownership Trust as a US Citizen: Why a UK-Exempt Exit Can Still Cost Full US Tax
EOT relief is a UK exemption. The US taxes its citizens on the whole gain - and where the UK charges nothing, there is no UK tax to credit against it.
Bare trusts and designated accounts for children in the UK: parental settlement rule, kiddie tax and US reporting for American families
US-UK
Bare Trusts and Designated Accounts for Children: The UK's Default Way to Save for a Child, and What It Means for an American Family
The child owns a bare trust absolutely and is normally taxed on it - but who funded it decides the UK answer, and a US-citizen child brings a filing history of their own.
UK betting, lottery and spread-betting winnings and US tax reporting for US persons in Britain
US-UK
UK Betting, Lottery and Spread-Betting Winnings When You Are a US Person: Tax-Free in Britain, Reportable in America
Britain does not tax the punter. America taxes the winnings - and because HMRC collected nothing, there is no foreign tax credit to soften it.
Family investment company with a US citizen shareholder: CFC rules, Form 5471 and UK inheritance tax exposure
US-UK
Family Investment Companies and the US Person: Why a UK Succession Structure Can Create Immediate American Tax
A FIC defers UK tax and passes value down - but to the IRS it is a foreign corporation, and the US family member can be taxed on income never distributed.
Giving up a US green card: how abandoning permanent residence affects US tax residence and expatriation exposure
US
Giving Up a Green Card: The Tax Side of Handing Back US Permanent Residence
Abandoning a green card does not automatically end US tax residence - and long-term residents can face the same expatriation rules as citizens who renounce.
Proving US and UK tax residence for treaty claims: IRS Form 6166 and HMRC's certificate of residence
US-UK
Proving Where You Are Tax Resident: IRS Form 6166, Form 8802 and HMRC's Certificate of Residence
How to get a US residency certificate on Form 8802 and a UK certificate of residence from HMRC - the fees, the lead times, and why requests get refused.
1099 contractor vs W-2 employee classification, US tax compliance
US
Worker Classification: 1099 Contractor vs. W-2 Employee—and What Misclassification Costs Your Business
Get the IRS tests for contractor status wrong, and you face back taxes, penalties, and audits. Here's how to classify correctly.
Tax equalisation for US executives on UK assignment: hypothetical tax, gross-ups and uncovered personal income
US-UK
Tax Equalisation for Americans on UK Assignment: What the Policy Promises, and Where Executives Still Get Caught
Hypothetical tax, gross-ups and the year-end true-up explained - plus the income your employer's equalisation policy almost certainly does not cover.
Inheriting a UK pension as a US person: how UK death benefit rules and US income tax rules treat the same money differently
US-UK
Inheriting a UK Pension When You Are a US Person: How Two Tax Systems Treat the Same Money
A UK pension death benefit can be tax-free in Britain and taxable in America, with no credit to soften it. What a US beneficiary should know first.
Returning to the US after years in the UK: split-year treatment, temporary non-residence and the repatriation tax year
US-UK
Moving Back to the US After Years in the UK: The Repatriation Year, and What to Do Before You Fly
Split-year treatment, temporary non-residence, ISAs, SIPPs and the UK house — plus the US side: the FEIE ending, state residency restarting, credits expiring.
SAYE Sharesave and SIP share schemes for US citizens in the UK: UK tax-advantaged plans that still create a US tax bill
US-UK
SAYE and SIP for US Citizens Working in the UK: Why a UK-Tax-Free Share Scheme Can Still Cost You in America
Sharesave and Share Incentive Plans are tax-advantaged under UK law only. The US taxes them on its own terms, at its own moments, with no UK tax to credit.
Cross-border trust planning: US, UK, UAE tax comparison for expats and founders
Cross-border
Trusts Across Borders: How the US, UK, and UAE Tax Trusts Differently—And Why Your Family Structure Matters
Cross-border families face vastly different trust rules in each jurisdiction. Here's what you need to know.
Digital nomad working on laptop at luxury co-working space, world map and tax documents visible, representing cross-border tax residence
Cross-border
The 183-Day Rule Is a Myth: What Really Triggers Tax Residence for Digital Nomads
The day-count rule is misleading. Tax residence depends on ties, intent, and treaty provisions—not a simple threshold.
Beneficial ownership registers and cross-border transparency across USA, UK, UAE jurisdictions
Cross-border
Beneficial Ownership Registers and Cross-Border Transparency: What Business Owners Must Know in 2024
Navigate BO reporting across the USA, UK, and UAE. Essential compliance rules, filing deadlines, and penalties explained.
UK trading losses relief guide—carry back, forward, sideways loss mechanisms
UK
UK Trading Losses: Carry Back, Forward and Sideways—A Complete Guide for Business Owners
Master how to offset UK company losses against profits in prior years, future years, and other income streams to minimise tax.
529 college savings plans for American families in the UK: US tax-free education account and the UK tax question
US-UK
529 Plans for American Families in the UK: What HMRC Makes of a US Tax-Free Education Account
A 529 is tax-free in the US, but the UK may not agree. The UK risk, UK universities, ownership, and 529 vs Junior ISA.
Cross-border divorce tax for US citizens in the UK: asset transfers, the family home, pensions and maintenance
US-UK
Divorce for Americans in the UK: The Cross-Border Tax Consequences Settlements Routinely Miss
An English divorce settlement can carry US tax consequences. Asset transfers, the home, pension sharing, maintenance and FBAR for American spouses in the UK.
Charitable giving for US-UK dual taxpayers: Gift Aid, US charitable deductions and dual-qualified charities
US-UK
Charitable Giving When You Pay Tax in Both the US and UK: Why One Gift Can Earn Relief in Only One Country
Gift Aid needs a UK charity; a US deduction needs a US one. How dual taxpayers give well: dual-qualified charities, shares, legacies and records.
Venture Capital Trusts for US citizens in the UK: UK tax reliefs versus US PFIC reporting and taxation
US-UK
Venture Capital Trusts for US Citizens in the UK: Why a UK Tax Break Can Become a US PFIC Problem
UK VCT reliefs do not cross the Atlantic. Why the IRS likely treats a VCT as a PFIC, taxes its dividends, and how the relief can erode your foreign tax credit.
Professional business professionals in Dubai and London offices planning cross-border employee secondment tax strategy
Cross-border
Secondments and Short-Term Assignments: Essential Tax Guide for Cross-Border Employee Mobility
Navigate tax residency, social security, and withholding rules when deploying staff across borders—US, UK, and UAE.
Business owner signing exit agreement, UK business asset disposal relief concept
UK
Business Asset Disposal Relief in the UK: Maximise Your Exit with Lower Capital Gains Tax
Understand BADR eligibility, trading company status and the £1m lifetime limit to cut your CGT rate on business sale.
UAE corporate tax compliance for freelancers and business owners in Dubai
UAE
Corporate Tax for Freelancers and Natural Persons in the UAE: Your Complete Guide
Understand UAE corporate tax filing, personal income rules, and compliance requirements for freelancers and business owners.
UAE free zone warehouse with container goods, designated zone VAT concepts
UAE
Designated Zones and UAE VAT: When Goods Movements Fall Outside the Scope
How special economic zones, free zones, and offshore areas affect VAT liability—and why exemptions don't always apply.
Currency exchange gains and losses across US, UK, UAE jurisdictions, cross-border tax
Cross-border
Currency Exchange Gains and Losses: The Hidden Cross-Border Tax You're Probably Missing
FX movements create taxable gains and losses. Learn how the IRS, HMRC and UAE treat them—and why most expats get it wrong.
UK holding company structure diagram with gold accents on navy background
UK
UK Holding Companies: When They Make Financial Sense and What They Really Cost
A practical guide to whether a holding company structure saves you tax, protects your assets, and justifies the setup and ongoing costs.
UK holding company structure: dark professional setting with financial documents and corporate governance symbols
UK
UK Holding Company Structure: When It Makes Sense and What You'll Actually Pay
A practical guide to holding company benefits, real costs, and whether this structure suits your business.
US tax for Americans living in Dubai: why zero UAE personal income tax still leaves a US filing and tax liability
US-UAE
US Taxes for Americans Living in Dubai: Why Zero UAE Income Tax Does Not Mean Zero US Tax
No US-UAE treaty and no UAE income tax means no foreign tax credit. What the FEIE covers, what it misses, and the FBAR and 5471 duties expats miss.
UK inheritance tax long-term residence test for US citizens in Britain, where UK IHT and US estate tax overlap
US-UK
UK Inheritance Tax After Domicile: What the Long-Term Residence Test Means for a US Citizen in Britain
From 6 April 2025 UK inheritance tax follows residence, not domicile. What the 10-of-20-year test means for US citizens in Britain, and where US tax bites.
Carried interest for US citizens working in UK private equity, venture capital and hedge funds: US-UK cross-border tax treatment
US-UK
Carried Interest for US Citizens in UK Funds: How the Two Systems Now Collide
UK carried interest moved into the Income Tax framework in April 2026. What that means for US citizens in London funds, and why foreign tax credits misfire.
EMI share options held by US citizens working in the UK: how UK and US tax rules apply to grant, exercise and sale
US-UK
EMI Share Options and US Citizens in the UK: Why the UK Relief Does Not Carry Across
EMI is a creature of UK statute and the US does not recognise it. How grant, exercise and exit are taxed on different timelines for American holders.
Global e-commerce tax compliance: sales tax, VAT, and corporate tax across US, UK, UAE
Cross-border
Cross-Border E-Commerce Tax: Navigate Sales Tax, VAT & Corporate Tax Across Borders
Master the tax compliance maze for digital sales spanning US, UK, and UAE—practical strategies for founders selling globally.
US tax forms and FBAR amendments for expats filing streamlined disclosures
US
Can You Amend a Streamlined Submission After Filing? What to Do If You Spot an Error
How to correct mistakes in a Streamlined disclosure and whether you can amend after submission—expert guidance for US expats and business owners.
US 401(k) and IRA accounts for Americans living in the UK: how the US-UK tax treaty taxes growth and withdrawals
US-UK
Keeping a US 401(k) or IRA After Moving to the UK: How Each Country Taxes It
Moving to Britain with a 401(k) or IRA? How the US-UK treaty taxes growth and withdrawals, why UK pension transfers rarely work, and the costly mistakes.
Selling a US home after moving to the UK: US home-sale exclusion, UK capital gains tax and FIRPTA
US-UK
Selling Your US Home After Moving to the UK: Exclusion, CGT and Timing
Selling a US home after moving to the UK: how the US exclusion clock, UK capital gains tax, FIRPTA and exchange rates decide what you pay.
US citizen partner in a UK LLP: US and UK tax treatment for members of London law, accountancy and fund firms
US-UK
US Citizens as Partners in a UK LLP: How Both Countries Tax You
A UK LLP is transparent for HMRC, but US classification is separate and fact-dependent. What US citizen partners in London firms must file and why.
Junior ISA and Child Trust Fund savings for US citizen children in the UK: US tax, PFIC and FBAR reporting
US-UK
Junior ISAs and Child Trust Funds for US Citizen Children: The Hidden US Tax Problem
A Junior ISA or Child Trust Fund is tax-free in the UK, not the US. What it means for a US citizen child: US income, PFIC rules, the FBAR and how to fix it.
US tax compliance for foreign corporation owners: Form 5471 filing guide
US
Form 5471 Filing Categories Decoded: Which One Applies to Your US-Owned Foreign Corporation?
A step-by-step guide to identifying your Form 5471 category and meeting IRS reporting obligations for US owners of foreign corporations.
Married couple reviewing US tax documents with laptop; mixed-status joint return and compliance planning.
US
Joint Tax Returns with a Non-Resident Spouse: US Filing, Eligibility & Mixed-Status Strategy
How married couples with mixed citizenship or residency navigate US joint returns, separate filing, and streamlined compliance.
US expat holding UK life insurance bond paperwork, London financial district background
Cross-border
US Tax Reporting for UK Life Insurance Bonds and Investment Wrappers: A Complete Guide for Expats
UK life insurance bonds and investment wrappers trigger complex US tax reporting. Learn what you owe, when to file, and how to avoid penalties.
Form 5471 filing decision tree for US shareholders in foreign corporations
US
Form 5471 Filing Categories Explained: A Step-by-Step Decision Tree for US Business Owners
Determine your correct Form 5471 category and filing obligation with our straightforward decision framework for US shareholders in foreign corporations.
US citizen reviewing UK property documents with calculator and pound sterling currency symbols
Cross-border
Buying a UK Home as a US Citizen: Tax, Mortgages and Currency Risk Explained
US citizens purchasing UK property face dual tax obligations, currency exposure and FIRPTA rules. A strategic plan protects your investment.
Cross-border inheritance US tax Form 3520 compliance for expats
Cross-border
Inheriting Money from Overseas as a US Person: The Form 3520 Trap and How to Avoid It
US persons who inherit foreign assets face severe penalties if they miss Form 3520 filing. Here's what you need to know.
Executor reviewing US tax and estate papers for a relative who died abroad, UK estate administration
US
Filing US Taxes for a Relative Who Died Abroad: An Executor's Guide
A relative who died abroad was a US citizen or green-card holder? An executor's guide to the final return, unfiled years, FBARs and US estate tax.
Temporary Repatriation Facility planning for US citizens in the UK: modelling the UK charge against US tax relief
US-UK
The Temporary Repatriation Facility and the US Citizen: the Double-Tax Trap
The UK's Temporary Repatriation Facility is priced for UK-only taxpayers. US citizens may get no foreign tax credit for the charge — model both sides first.
Premium Bonds and NS&I accounts: FBAR and US tax reporting for American expats living in the United Kingdom
US-UK
Premium Bonds and the FBAR: What US Persons in the UK Must Report
Premium Bond prizes are tax-free in the UK but not in the US. What a US person in Britain reports on the FBAR and Form 8938 — and what to do if they haven't.
UK Self Assessment and US Form 1040 side by side, modelling the FIG regime for a US citizen in the UK
US-UK
The UK's FIG Regime and US Citizens: Why the Relief Often Goes to the IRS
The FIG regime replaced the non-dom remittance basis — but for a US citizen the UK exemption removes the foreign tax credit too, handing the benefit to the IRS.
US citizen abroad weighing filing options with a non-American spouse: married filing separately or a joint election
US
Married to a Non-American: How US Citizens Abroad File With a Foreign Spouse
How a US citizen abroad files with a non-American spouse: Married Filing Separately, the 6013(g) election, ITINs, joint-account FBARs and fixing past years.
A US residential rental property owned from the United Kingdom, illustrating US-UK cross-border taxation of American rental income
US-UK
US Rental Property as a UK Resident: How Both Countries Tax the Income — and the Sale
How US rental income and the eventual sale are taxed for UK residents — Schedule E vs Self Assessment, depreciation mismatches, FIRPTA and UK CGT in sterling.
Remote professional in a London home office working for a US employer - US-UK tax and payroll issues
US-UK
Working Remotely From the UK for a US Employer: Tax, Payroll and Treaty Issues
What happens to tax and payroll when you work remotely from the UK for a US company — SRT residence, FEIE vs foreign tax credit, PAYE, NIC and PE risk.
An American retiree abroad reviewing pension statements and IRS streamlined filing paperwork with an adviser
US
Retired Abroad and Haven't Filed US Taxes? The Streamlined Route Back
Why American retirees abroad still owe the IRS a return, how pensions and Social Security are treated, and why the Streamlined Foreign Offshore Procedures fit retirees so well.