The Journal

Tax & Accounting, Clearly Explained

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

Brass key and folded title deeds on a navy leather desk: selling a UK main home as a US citizen, PRR versus section 121
US-UK
Selling Your UK Main Home as a US Citizen
UK Private Residence Relief is uncapped; the US section 121 exclusion is not. How a tax-free London sale still produces a US bill with nothing to credit.
Navy leather day-diary and gold pen on dark wood, for the UK Statutory Residence Test as it applies to US citizens
US-UK
The UK Statutory Residence Test, Step by Step
The Statutory Residence Test decides whether the UK can tax you. It does not touch your US filing duty. The three parts, in order, with the day counts.
Brass balance scales and a navy ledger on dark walnut: US and UK capital loss relief for cross-border investors
US-UK
Capital Losses: Why the US and UK Count Them Differently
A loss that shelters tax in one country can be a taxable gain in the other. The offset rules, the currency mismatch, and how to harvest safely.
Navy leather folio, gold pen and brass key on a dark desk: UK Trust Registration Service rules for US-connected trusts
US-UK
UK Trust Registration Service and US Trusts
TRS is a transparency register, not a tax return, and a US revocable trust can fall into it by buying UK property. The gateways and the privacy cost.
Navy folio and gold pen on a dark desk: US tax treatment of UK and offshore investment bonds for US citizens
US-UK
Offshore Investment Bonds and the US Citizen Problem
UK and offshore investment bonds rest on UK reliefs the IRS does not recognise. The section 7702 analysis, PFIC risk, excise tax and reporting, explained.
Brass pen on a navy ledger, for the Form 8621 PFIC election — QEF or mark-to-market for US taxpayers in the UK
US-UK
Form 8621: QEF vs Mark-to-Market vs Section 1291
How the three PFIC regimes work in practice, why QEF is rarely available on UK funds, and what the section 1291 interest charge does to a long holding.
Gilt-framed canvas and antique bronze on a dark navy gallery wall: US and UK tax on art, antiques and collectibles
US-UK
Art, Antiques and Collectibles: The US and UK Tax Position
The US caps collectibles gains at 28%. The UK treats the same objects as chattels and exempts some entirely. How the two systems diverge for collectors.
Gold-nibbed pen and brass desk clock on navy leather, for the US section 6013(g) election for a British spouse
US-UK
Section 6013(g): Treating an NRA Spouse as US Resident
Married filing separately, head of household or the election: what each does to a British spouse's worldwide income, and why revoking is permanent.
Brass desk clock and navy leather ledger in low gold light: Roth conversion tax treatment for UK-resident US taxpayers
US-UK
Roth Conversions While UK Resident: The Treaty
The US tax on converting a traditional IRA or 401(k) is clear. Whether HMRC taxes the same conversion is not. The treaty analysis, article by article.
Gold fountain pen and closed navy portfolio on a dark walnut desk, for US founders in the UK selling QSBS shares
US-UK
QSBS Section 1202 for US Founders Living in the UK
Section 1202 can make a US founder's exit tax-free in America and fully taxable in Britain. How the QSBS exclusion collides with UK capital gains tax.
Navy leather portfolio and brass lamp still life: private equity and hedge fund tax reporting for US citizens in the UK
US-UK
PE and Hedge Funds for US Citizens in the UK
Late K-1s, reporting versus non-reporting fund status, offshore income gains taxed as income, and the PFIC trap sitting inside most offshore funds.
Brass keys and a folded wool scarf, for US citizens reporting UK employment benefits in kind on a US tax return
US-UK
UK Benefits in Kind on Your US Tax Return
Your P11D is a UK measure, not a US one. How company cars, medical cover, pensions, loans, relocation and childcare land on a US return, one by one.
An empty leather chair, for US executives in the UK with deferred compensation under section 409A
US-UK
Section 409A and UK Executives: Deferred Pay for US Citizens
Section 409A follows US citizens wherever they work, so an ordinary UK deferred bonus or cash LTIP can fail it. What a failure costs, and what to check.
A closed brass-bound wooden chest, for UK residents who are beneficiaries of a US family trust
US-UK
US Trusts and UK Resident Beneficiaries: How the Tax Works
A US family trust is paying out and you are UK resident. How HMRC characterises what reaches you, matched gains, and the supplementary charge.
Two plain gold wedding bands, for US citizens leaving assets to a non-US-citizen spouse under the QDOT rules
US-UK
QDOT Rules: Leaving Assets to a Non-US-Citizen Spouse
The unlimited marital deduction generally fails where the surviving spouse is not a US citizen. How a QDOT works, what it costs, and the alternatives.
A young olive sapling, for US citizens weighing EIS and SEIS investments in UK startups
US-UK
EIS and SEIS Relief: Why US Citizens Still Pay Tax
UK income tax relief and a CGT-free exit mean nothing to the IRS, and often leave no credit to absorb the US bill. The PFIC test, stated precisely.
An open brass padlock and key, representing the repeal of the Windfall Elimination Provision for people with UK pensions
US-UK
WEP Repeal: Your UK Pension and US Social Security
The Windfall Elimination Provision and GPO are gone. What changed, who gains, what the SSA has already paid out, and why a bigger benefit is still taxed.
An English stone farmhouse and barn, for US citizens inheriting or owning UK business and agricultural property
US-UK
Business Property Relief and US Citizens: the 2026 Rules
The UK now caps full Business and Agricultural Property Relief. Neither relief exists in US law, so transatlantic owners must check both sides.
The Houses of Parliament and Big Ben at blue hour, for US citizens in Britain watching the UK Budget on 28 October 2026
US-UK
UK Budget 2026: What US Citizens in Britain Should Watch
What is already law, what has only been announced, and why a UK rate change moves your US bill through the foreign tax credit rather than leaving it.
A closed navy folder alone, for Americans abroad who cannot pay an IRS tax bill in full
US
Can't Pay Your IRS Tax Bill From Abroad? Your Options
File anyway, then pick your route. IRS payment plans, offers in compromise, currently not collectible status and penalty relief for Americans abroad who cannot fund the balance.
A brass model ship, representing a US person transferring cash or property to a foreign corporation on Form 926
US-UK
Form 926: Funding A UK Company As A US Citizen
Funding your own UK limited company is a transfer of property to a foreign corporation. When Form 926 is required, how the 10% and $100,000 cash tests work, and what the penalty really costs.
A brass hourglass, representing an HMRC Time to Pay arrangement for Self Assessment
UK
HMRC Time to Pay: Self Assessment Payment Plans Explained
Cannot pay your Self Assessment bill? How a Time to Pay arrangement works, who can set one up online without calling, and which penalties it stops.
An English garden bench, for expats buying UK State Pension years with voluntary National Insurance contributions
UK
Voluntary National Insurance From Abroad: 2026 Rules Explained
Class 2 for time abroad ended on 6 April 2026. What expats can still pay, the new 10-year Class 3 gate, CF83, the deadlines, and whether buying UK State Pension years is worth it.
A brass service bell, representing mandatory HMRC registration for tax advisers from 2026
UK
Is Your Tax Adviser Registered With HMRC? The 2026 Rules
How to check your accountant is registered with HMRC, AML-supervised and genuinely qualified, and what the staged registration windows mean for you.
A fan of blank cream pages, representing the SA109 residence and other supplementary Self Assessment pages
US-UK
SA109 Residence Pages: A Guide for US Citizens in the UK
What the SA109 residence pages cover, why HMRC's own online service cannot file them, and which supplementary pages an American in the UK needs too.
Two closed navy folders stacked, representing the order in which US and UK tax returns are prepared
US-UK
Which Tax Return To File First, The US Or The UK?
The UK tax year runs 6 April to 5 April and the US year is the calendar year, so one UK year straddles two US returns. How to sequence them, apportion correctly and time the foreign tax credit.
A gold staircase with one step rising far higher than the rest, representing the UK 60% tax trap where the personal
US-UK
The UK 60% Tax Trap, and What It Means for US Citizens
Why income between £100,000 and £125,140 is taxed at about 60% in the UK, how to reduce adjusted net income, and why the obvious fix can raise a US citizen's IRS bill.
A graduation mortarboard, for Americans abroad repaying US federal student loans
US
US Student Loans While Living Abroad: FEIE and IDR Payments
How the foreign earned income exclusion cuts adjusted gross income — and with it your income-driven student loan payment — plus the trade-off against the foreign tax credit, under the 2026 rules.
A home-working desk, for UK employees of a foreign employer running a DPNI scheme
UK
DPNI Scheme: UK PAYE When Your Employer Has No UK Presence
If you work in the UK for a US company with no UK presence, you operate PAYE yourself under a DPNI direct payment scheme. Which scheme applies, who owes employer's NIC, and how to register.
A small London office at dusk with two desks and an unlabelled world map, for UK companies paying contractors based in
US-UK
UK Company Paying US Contractors: 1099s, Tax and Traps
A UK limited company with no US presence generally has no Form 1099-NEC duty. What does bite: worker classification, W-9 records, permanent establishment, VAT reverse charge and corporation tax.
A brass magnifying glass resting, for Americans abroad checking their IRS account transcripts
US
IRS Transcripts From Abroad: See What the IRS Has on File
The five IRS transcript types, how far back each goes, and every way to get them from outside the US when ID.me, a foreign address and a non-US phone stand in the way.
A Victorian terraced house on a quiet British street at dusk, warm lamplight, illustrating US tax treatment of UK home
US-UK
UK Mortgage Interest on a US Tax Return: What Counts
Interest on a UK mortgage is deductible on a Form 1040 — but only if you itemise, and council tax never is. The acquisition-debt limits, the standard deduction maths and the housing exclusion.
Desk of a UK consultant at dusk with laptop, invoices and fountain pen, representing UK contractors and limited
US-UK
W-8BEN for UK Contractors Invoicing US Clients
Work done in the UK for a US client is foreign-source: no US tax, no 1099-NEC. Why your client needs a W-8BEN or W-8BEN-E rather than a W-9, and what changes when you work in the US.
A FATCA self-certification letter from a UK bank, illustrating US person status checks for accidental Americans in the
US-UK
Your UK Bank Asked If You Are a US Person: What the Letter Means
Why UK banks, brokers and pension providers write asking about US status, exactly what is reported to HMRC and the IRS, and what accidental Americans should do before signing anything.
A quiet private-bank study at dusk, for US Roth IRA retirement savings held by a UK-resident owner
US-UK
Roth IRA Tax for UK Residents: What the Treaty Actually Says
A qualified Roth distribution should be exempt in the UK under Article 17(1)(b), and the saving clause cannot claw it back. What HMRC has published, what it has not, and where conversions stand.
An empty panelled boardroom, representing where a company board actually takes its decisions
US-UK
UK Company, US Director: Where Is It Tax Resident?
A UK company stays UK resident by incorporation. What a US-based director changes is US permanent establishment risk — and, in harder cases, dual residence the treaty sends to both authorities.
Two brass weights and a smooth stone, representing the choice a US owner of a UK company makes on the section 962
US-UK
Section 962 Election: US Owners of a UK Company
A US citizen owning a UK limited company can elect under section 962 to be taxed on the CFC inclusion at corporate rates and credit UK corporation tax. When that helps, and when it costs you.
A plain sealed envelope, representing an HMRC nudge letter about offshore income
UK
HMRC Nudge Letters on Offshore Income: How to Respond
HMRC letters about overseas income come from CRS and FATCA data. What the certificate of tax position really is, how the Worldwide Disclosure Facility works, and the penalties that apply.
A phone, plain bank card and cup of coffee, for Americans abroad paying the IRS without a US bank account
US
How to Pay the IRS From Abroad Without a US Bank Account
Every way to pay US federal tax from overseas, compared: international wires, approved card processors, checks, penalties, payment plans and what happens to refunds when you have no US account.
A brass desk bell and folded navy cloth, representing a formal treaty position disclosure to the IRS on Form 8833
US-UK
Form 8833: When to Disclose a US-UK Treaty Position
Form 8833 discloses a treaty position that overrules the Internal Revenue Code. When it is required, the long list of waivers, the $1,000 penalty, and the green card tie-breaker trap.
An American waterfront house at sunset, for UK residents selling US property under FIRPTA withholding
US-UK
FIRPTA Withholding When a UK Resident Sells US Property
The buyer withholds a slice of your gross US sale price. How Form 8288-B cuts it before completion, how the refund works, and how the UK taxes the gain.
A quiet English country house library at dusk, for UK families holding US shares or property
US-UK
US Estate Tax for UK Residents Who Own US Shares or Property
UK residents who are not US citizens face US estate tax above just $60,000 of US-situated assets. How situs works, what the 1978 treaty exempts, and how to claim it in time.
A founder's desk at dusk, for UK residents who own a US LLC
US-UK
US LLCs and UK Residents: The Tax Mismatch After Anson
The US treats most LLCs as transparent; HMRC treats them as companies. That mismatch can break double tax relief. What Anson decided, what HMRC says, and the reform now consulted on.
Stacks of gold coins beside a young olive tree on a walnut desk, representing UK dividends reported on a US tax return
US-UK
UK Dividends on a US Return: Qualified Rates and FTC
When UK dividends get the lower US rates, how UK tax becomes a credit on Form 1116, and why the net investment income tax still reaches Americans abroad.
A London townhouse study at dusk with a laptop, brass lamp and small bronze bull, for Americans keeping a US brokerage
US-UK
Keeping a US Brokerage Account After Moving to the UK
Moving to Britain with a US brokerage account? How the UK taxes US shares and ETFs, W-9 vs W-8BEN, treaty withholding, reporting funds and the PFIC mirror trap.
Two teacups, for Americans retiring in the UK with US Social Security benefits
US-UK
US Social Security While Living in the UK: Who Taxes It?
How the US-UK treaty taxes US Social Security for UK residents, including US citizens, how to stop 25.5% withholding, and how a UK State Pension is taxed in the US.
A warm English family living room with wooden toys and picture books, for Americans in the UK claiming the US Child Tax
US-UK
Child Tax Credit for Americans in the UK: FEIE vs FTC
US parents in the UK can claim up to $2,200 per child, $1,700 refundable, but not if they file Form 2555. How the Foreign Tax Credit route can unlock a refund.
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 UK Tax Planning for Wealthy Americans
UK residence switches on worldwide taxation from a date the statute fixes. The choices that exist only in the months before you land, in order.
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
UK Non-Executive Director Fees and US Tax
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
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 Wins and the US Taxpayer
Britain does not tax the punter. America taxes the winnings - and because HMRC collected nothing, there is no foreign tax credit to soften it.