Who needs a US-UK tax accountant for founders, fund managers and executives?
You need a US-UK tax accountant for founders, fund managers or executives when you are taxed by both countries and your income comes through a company, a partnership or shares rather than a simple salary. That describes three groups: US persons who own UK companies, US persons who share in a UK fund's carry, and executives whose equity pay or partnership income crosses the border.
A US person is a US citizen, a Green Card holder or anyone else who is resident in the US for tax. The US taxes its citizens and Green Card holders on worldwide income wherever they live. The UK taxes its residents on worldwide income too. If you are both, each country starts from the position that everything is taxable, and relief comes only from foreign tax credits and the US-UK double taxation treaty.
Credits and the treaty work well for a salary. They work badly, without care, for the items on this page. Each country has its own rules for when income arises, what kind of income it is and who earned it. A credit only helps when both countries tax the same income, of the same type, in years that can be matched. A UK company, a carried interest or a share option can fail any of those three tests.
The three groups and their main pressure points
| Who you are | Main US issues | Main UK issues |
|---|---|---|
| US-person founder of a UK company | Form 5471, Subpart F, GILTI (now net CFC tested income), section 962, entity elections, no QSBS | Corporation tax, salary versus dividends, director's loans, Business Asset Disposal Relief |
| US-person fund manager or partner | Section 1061, Schedules K-1 and K-3, Form 8865, PFICs, Net Investment Income Tax | Carried interest as trading income from 6 April 2026, disguised management fees, LLP rules |
| Executive with cross-border equity or K-1s | Tax at vest or exercise, section 83(b), section 409A, state returns | PAYE at vest or exercise, sourcing by workdays, pension annual allowance, the new arrivals regime |
Most firms know one of these columns well. A UK accountant optimises the UK column and has never seen a Form 5471. A US preparer files the forms and takes the UK numbers as given. The expensive mistakes sit between the columns, which is why this page covers both for every item. For the ordinary mechanics of filing in both countries, start with our guide to US and UK tax returns.
US UK Tax Experts prepares the US return and the UK return from one file, so the two agree. Where a choice on one return changes the other, we work it through on both before anything is filed.
What does a US person who owns a UK limited company have to file?
A US person who owns 10% or more of a UK limited company must usually file Form 5471 with their US return every year, and if US shareholders together own more than 50%, the company is a controlled foreign corporation whose profits can be taxed to them personally before any dividend is paid. This is on top of the company's UK accounts, corporation tax return and Companies House filings.
When is a UK company a controlled foreign corporation?
A controlled foreign corporation (CFC) is a foreign company in which US shareholders own more than 50% of the votes or the value on any day of its tax year. A US shareholder, for this test, is a US person who owns 10% or more of the votes or value. Ownership includes shares held through other entities and shares attributed from certain family members.
Two points catch founders out. First, exactly 50% is not control. A company owned equally by a US founder and an unrelated UK co-founder is not a CFC. Second, shares owned by a spouse who is a non-resident alien are not attributed to the US spouse under the family rules. A couple who each own half, where only one is a US person, usually do not have a CFC. That company may then fall into the PFIC rules instead if it holds mainly cash or investments, so escaping CFC status is not always a win.
Form 5471: categories of filer
Form 5471 is the IRS information return for US persons who are officers, directors or shareholders of certain foreign corporations. The IRS instructions for Form 5471 (revised December 2025) sort filers into categories, and the category decides which schedules you complete.
| Category | Who it covers | Typical founder case |
|---|---|---|
| 1 | US shareholders of a specified foreign corporation under the 2017 transition tax rules | Rarely relevant to a new company |
| 2 | A US officer or director of a foreign company in which a US person acquires 10% or more | A US director when a US investor comes in |
| 3 | A US person who acquires 10% or more, or drops below 10% | The year you form or buy into the company |
| 4 | A US person who controlled the company (more than 50%) during its accounting period | The sole or majority founder, every year |
| 5 | A US shareholder of a CFC | Any 10% US shareholder of a CFC, every year |
A sole US founder is normally a Category 4 and Category 5 filer each year, and Category 3 in the year of formation. That means the full form: the company's balance sheet and income statement restated under US accounting principles in US dollars, plus schedules for earnings and profits (Schedules H and J), taxes paid (Schedule E), transactions with you and related parties (Schedule M), previously taxed earnings (Schedule P), the income groups used for the tested income and high-tax calculations (Schedule Q) and distributions (Schedule R). Schedule I-1 computes the tested income that feeds Form 8992. Schedule O reports the formation and share acquisitions.
The form is attached to your Form 1040 and is due when that return is due, including extensions. It is not optional because the company is small, dormant or loss-making, although a dormant company can use a shortened filing.
What is the penalty for not filing Form 5471?
The penalty for failing to file a complete Form 5471 is $10,000 for each form for each year. If the IRS sends a notice and the form is still not filed within 90 days, a further $10,000 is added for each 30 days, up to an additional $50,000. Foreign tax credits can also be cut by 10%.
The penalty is the smaller problem. Under section 6501(c)(8), the time the IRS has to assess tax on your return does not start to run until the form is filed. A missing Form 5471 can keep the whole year's return open indefinitely, or only the items linked to the form if you show reasonable cause. A return you thought closed years ago may not be.
You may have read that the courts stopped the IRS from assessing this penalty. The Tax Court held that in Farhy in 2023, but the Court of Appeals for the D.C. Circuit reversed it in May 2024. The Tax Court has since kept to its own view in cases that would be appealed elsewhere, so the point is unsettled. It is not a reason to skip the form.
If you have owned a UK company for years without filing, the usual fix is the IRS streamlined procedures, covered in our guide to IRS streamlined filing. A UK company bank account you can sign on is also reportable on its own, which our FBAR and FATCA guide explains.
How does GILTI tax a UK company's profits, and what changed for 2026?
GILTI taxes a US shareholder each year on their share of a controlled foreign corporation's active profits, whether or not the company pays a dividend. For company tax years beginning after 31 December 2025 the regime is renamed net CFC tested income, the exclusion for a return on tangible assets is removed, and the deduction and credit percentages change.
Subpart F: the older rule for passive and related-party income
Subpart F income is a CFC's passive and easily moved income, which US shareholders must include in their own income in the year the company earns it. It covers dividends, interest, rents, royalties and investment gains, and some sales and services income involving related parties. A UK trading company with customers of its own usually has little. A company that holds investments, lends its surplus cash or bills for services performed for a related business can have a lot. If Subpart F income is under the lesser of 5% of gross income or $1 million, it is ignored.
GILTI up to 2025
GILTI stands for global intangible low-taxed income. For CFC tax years beginning before 1 January 2026, it is the company's tested income (broadly, profit that is not Subpart F income) less a deemed 10% return on its tangible business assets, known as QBAI. A US company that owns the CFC deducts 50% of the inclusion and credits 80% of the foreign tax. An individual gets neither by default. You are taxed on the inclusion at ordinary rates up to 37%, with no credit for the UK corporation tax the company paid.
Net CFC tested income from 2026
The 2025 US budget legislation, the One Big Beautiful Bill Act signed on 4 July 2025, rewrote the regime. The changes apply to tax years of foreign corporations beginning after 31 December 2025, and to the US shareholder's tax year in which that company year ends. For a UK company with a calendar year, 2026 is the first year affected. For a company with a 31 March year end, it is the year beginning 1 April 2026.
| Item | CFC years beginning before 2026 | CFC years beginning after 2025 |
|---|---|---|
| Name | GILTI | Net CFC tested income (NCTI) |
| Tangible asset exclusion (10% of QBAI) | Yes | Removed |
| Section 250 deduction | 50% | 40% |
| US rate at the 21% corporate rate | 10.5% | 12.6% |
| Share of foreign tax allowed as credit | 80% | 90% |
| Foreign rate at which US tax is usually nil | 13.125% | 14% |
The corporate figures matter to individuals because of the section 962 election, covered in the next section. The loss of the tangible asset exclusion matters to founders whose companies own plant, vehicles or fitted premises. Until 2025 a 10% return on those assets escaped GILTI. From 2026 all tested income is in. The same legislation also limits which US expenses are set against this income when the foreign tax credit limit is computed, which helps credits go further.
The high-tax exception and why the UK rate matters
The high-tax exception lets US shareholders elect to leave out of tested income any income taxed abroad at an effective rate above 90% of the US corporate rate, which is 18.9%. The legislation did not change it. The election is made each year by the controlling US shareholders and covers every CFC they control.
The UK main rate of corporation tax is 25% for profits above £250,000. The small profits rate is 19% for profits of £50,000 or less, with marginal relief in between, as HMRC's corporation tax rates page sets out. On paper every UK rate clears 18.9%. In practice the test is not run on UK taxable profit. It compares UK tax with income computed under US rules.
That is where a small company slips under. Full expensing of equipment, enhanced research and development relief and brought-forward losses all cut UK tax without cutting US-measured income by the same amount. A company paying 19% on UK profits can show an effective rate of 15% on US-measured income. Take an example: a company with £40,000 of UK taxable profit pays £7,600. If US-measured income is £50,000 because a UK loss was used, the effective rate is 15.2%, the exception fails, and the full £50,000 is tested income for that year.
The exception is tested every year and for each business unit. We compute it on US numbers before relying on it, and keep the section 962 election ready for years when it fails.
Section 962 election, check-the-box or a US C corporation: which is best?
There is no single best structure: the high-tax exception or a section 962 election suits a founder who retains profits in a UK company taxed at 25%, a check-the-box election suits one who draws out nearly everything each year, and a US C corporation rarely helps unless US investors or a US exit are in view. The right answer depends on how much you retain, what you pay yourself and how you expect to sell.
The section 962 election
A section 962 election lets an individual be taxed on Subpart F and tested income as if they were a US corporation. You get the 21% corporate rate, the section 250 deduction and a credit for the company's own foreign tax, as section 962 of the Internal Revenue Code provides. It is made on your return, year by year. The cost comes later. When the company pays out those profits, the dividend is taxed again in the US to the extent it exceeds the US tax you paid under the election, which is often nil. Because the UK has a full income tax treaty with the US, that dividend is normally a qualified dividend taxed at up to 20%.
Check-the-box: the company as a disregarded entity
A check-the-box election treats an eligible foreign company as transparent for US tax. A UK private limited company is eligible; a UK public limited company is not. With one owner it becomes a disregarded entity. You file Form 8832 to elect, and then Form 8858 each year instead of Form 5471. Nothing changes in the UK: the company still pays corporation tax and you still pay UK tax on salary and dividends.
In the US, the company's profit is yours as it is earned, taxed at ordinary rates up to 37%. In exchange, the UK corporation tax becomes your own foreign tax credit, and so does UK tax on your salary and dividends. There is no GILTI, no Subpart F and no second layer on distribution. Three cautions apply. Make the election at formation, because electing later is a deemed liquidation that can trigger gain. Profits you retain in the company are taxed at up to 37% against a 25% credit. And the US sees you as self-employed, so you need a UK certificate of coverage to stay out of US self-employment tax.
Holding the company through a US C corporation
A US C corporation that owns the UK company pays US tax on net CFC tested income at 12.6% less a credit for 90% of UK tax, usually nil, and can receive dividends from the UK company free of US tax. But profits then pass through a US company on their way to you, and a US company run from the UK by a UK-resident founder can be UK tax resident as well, which the treaty resolves only by agreement between the two tax authorities. This route is mostly used when US venture investors require it. See the Delaware flip below.
A worked comparison
Take an example. Maya is a US citizen living in London who owns all of a UK company. In its year to 31 December 2026 it makes £400,000 before tax and pays £100,000 of UK corporation tax at 25%. She pays UK and US tax at the top rates. Figures are kept in pounds and ignore her salary, National Insurance and allowances.
| Route | US tax if profit is retained | Total tax if the £300,000 is then paid out |
|---|---|---|
| No election | Up to £111,000 (37% of £300,000), no credit for corporation tax | Highest: corporation tax, US tax on the inclusion and UK dividend tax, with relief for the last depending on timing |
| High-tax exception | Nil | About £229,450 (57.4%) |
| Section 962 election | Nil | About £229,450 (57.4%) |
| Disregarded entity | About £48,000 (37% of £400,000, less £100,000 credit) | About £218,050 (54.5%) |
Under section 962 the sum runs like this. The inclusion is £300,000 plus a £100,000 gross-up for the UK tax, which is £400,000. Less the 40% deduction, £240,000 is taxed at 21%, giving £50,400. The credit is 90% of £100,000, more than enough, so US tax is nil. When the £300,000 is later paid out, the UK charges dividend tax at 39.35%, which is £118,050. The US charges 20%, covered by credit for the UK tax, plus 3.8% Net Investment Income Tax of £11,400, which is not covered. Total: £100,000 plus £118,050 plus £11,400.
As a disregarded entity, Maya's US tax is 37% of £400,000, which is £148,000. If she draws the profits in the same year, UK tax of £218,050 covers it, and because she works in the business there is normally no Net Investment Income Tax. If she retains the profits, only the £100,000 of corporation tax is available and £48,000 of US tax falls due now.
The pattern holds more widely. Retain profits, and the exception or section 962 wins. Distribute everything, and transparency can win by the 3.8%. Sell the company, and the answer changes again, because a disregarded entity is sold as assets for US purposes. We run these numbers on both returns before an election is filed, as part of our business and corporate tax work.
Should a US founder take salary or dividends from a UK company?
For a US founder paying top rates, salary and employer pension contributions usually beat dividends once both countries are counted, even though dividends are the standard UK answer. The UK-optimal mix of a small salary and large dividends produces passive income that carries the US Net Investment Income Tax, and profits left in the company can be taxed in the US before you receive them.
How each country sees the two routes
| Payment | UK treatment (2026-27) | US treatment |
|---|---|---|
| Salary | Deductible for the company. Income tax up to 45%, employee National Insurance of 8% then 2%, employer National Insurance of 15% | Earned income. Reduces tested income. UK income tax credits in the general basket, usually in full. No Net Investment Income Tax |
| Dividend | Paid from profits after corporation tax. Taxed at 10.75%, 35.75% or 39.35% above the £500 allowance | Passive income at up to 20% if qualified, plus 3.8% Net Investment Income Tax. UK tax credits against the 20% only |
| Employer pension contribution | Deductible for the company, no income tax or National Insurance, within the annual allowance | Excluded from income under the treaty, up to US limits for a comparable plan |
| Retained profit | Corporation tax only, at 19% to 25% | Tested income or Subpart F income unless an exception or election applies |
The dividend rates are those HMRC publishes for 2026-27 on its tax on dividends page. The basic and higher rates each rose by two points from 6 April 2026.
Run the top-rate numbers on £100 of company profit. As salary, income tax, employee and employer National Insurance take about 53.9%. As a dividend, corporation tax at 25% and dividend tax at 39.35% take 54.5%. In the UK alone the two are close, and at lower incomes dividends win clearly. Add the US, and the dividend picks up 3.8% on the £75 distributed, taking it to about 57.4%. The salary picks up nothing, because UK income tax at 45% more than covers US tax at 37%.
Lower down the income scale the UK saving from dividends is larger and can still win. The point is that the question has to be asked on both returns. A UK accountant's standard advice of a salary at the personal allowance and the rest in dividends was not designed for a US person.
Employer pension contributions
An employer pension contribution is a payment by your company straight into your registered pension scheme. In the UK it is deductible for the company and free of income tax and National Insurance, within your annual allowance of £60,000 for 2026-27. In the US, Article 18 of the treaty lets a US citizen resident in the UK exclude contributions to a UK scheme, and the growth inside it, up to the limits that would apply to a comparable US plan. Those US limits are indexed each year. For a founder this is often the most efficient extraction in both countries at once. Our pensions service covers the reporting.
Director's loans
A director's loan is money you take from your company that is not salary, a dividend or an expense repayment. In the UK, if a loan is still outstanding nine months and one day after the company's year end, the company pays a temporary tax charge under section 455, repaid to the company when you repay the loan. The rate follows the higher dividend rate: 33.75% for loans made before 6 April 2026 and 35.75% for loans made from that date. A loan above £10,000 at low or no interest is also a taxable benefit. HMRC explains the rules in its director's loans guidance.
The US adds a rule most UK advisers never meet. A loan from a CFC to its US shareholder is an investment in US property under section 956. It can be taxed to you as if the company had paid out its untaxed earnings, up to the amount of the loan. A loan that was meant to defer UK dividend tax can create US income with no UK tax to credit against it.
EIS and SEIS relief against US treatment
The Enterprise Investment Scheme and Seed Enterprise Investment Scheme give UK investors income tax relief of 30% and 50% of the amount invested, and exempt the gain from Capital Gains Tax if the shares are held for three years. The US recognises none of it. There is no US deduction for the investment, and the gain is fully taxable in the US at up to 23.8%, with no UK tax to credit because the UK charged none. Deferral of other gains into EIS shares is ignored too.
A US investor must also test the company. An early-stage company that holds cash and earns interest before it has revenue can be a passive foreign investment company. With enough US ownership it can be a CFC. Ask for the information before you invest, not at exit.
National Insurance and the totalization agreement
The US-UK totalization agreement is the social security treaty that stops the same earnings bearing both UK National Insurance and US Social Security tax. It has been in force since 1985. An employee generally pays only where they work, and a self-employed person only where they live. An employee sent by their employer to the other country for five years or less can stay in their home system with a certificate of coverage.
As a director employed by your own UK company, you pay UK National Insurance and no US Social Security tax. If you have elected to treat the company as a disregarded entity, the US regards you as self-employed, so obtain a certificate of coverage from HMRC and keep it with your US return. National Insurance is not an income tax and cannot be claimed as a foreign tax credit.
How is a US founder taxed on selling a UK company?
A US founder living in the UK pays UK Capital Gains Tax first on selling a UK company, at 18% on the first £1 million of lifetime gains if Business Asset Disposal Relief applies and 24% above that for 2026-27, and then US tax at up to 20% less a credit for the UK tax, plus 3.8% Net Investment Income Tax. On a clean cash sale the total is usually the UK rate plus 3.8%. Earn-outs and share exchanges are where it goes wrong.
Business Asset Disposal Relief: current rates by date
Business Asset Disposal Relief is a UK relief that applies a lower rate of Capital Gains Tax to gains on selling a business or shares in your personal trading company, up to a lifetime limit of £1 million. For shares, you must generally have held at least 5% of the shares and votes and been an officer or employee for two years before the sale. HMRC's Business Asset Disposal Relief guidance gives the rates:
| Date of disposal | Rate with the relief | Higher rate of CGT without it |
|---|---|---|
| On or before 5 April 2025 | 10% | 20% (24% from 30 October 2024) |
| 6 April 2025 to 5 April 2026 | 14% | 24% |
| On or after 6 April 2026 | 18% | 24% |
At 18%, the relief is now worth at most £60,000 over a lifetime. It no longer drives the structure of a sale the way it did at 10%.
The US side of the same sale
The US taxes the gain as a long-term capital gain at up to 20% if you held the shares for more than a year, plus 3.8%. Your basis is measured in US dollars at the exchange rates on the dates you bought and sold, so the US gain is rarely the UK gain converted. If the company is a CFC, section 1248 treats part of the gain as a dividend up to its untaxed earnings. For an individual that usually changes the label more than the rate.
UK tax of 18% to 24% is credited against the 20%. Where the relief applies and UK tax is 18%, the US collects the extra two points. Either way the 3.8% is added. On a £5 million gain, that is about £190,000 that no credit removes.
Why the section 1202 QSBS exclusion does not apply to a UK company
Qualified small business stock (QSBS) is stock in a US C corporation, acquired at original issue, that meets an active business test and a gross assets limit. Under section 1202, gain on QSBS held for five years can be wholly excluded from US tax. For stock acquired after 4 July 2025 the exclusion is 50% after three years, 75% after four and 100% after five, the cap is the greater of $15 million or ten times basis, and the gross assets limit is $75 million.
The statute requires a domestic C corporation. A UK limited company is not one, whatever US election it has made, so its shares can never be QSBS. A founder who expects a large exit to US buyers sometimes puts a US parent on top for this reason. The UK gives no matching exemption, so a UK-resident founder still pays UK Capital Gains Tax on the whole gain.
Earn-outs
An earn-out is deferred sale consideration that depends on how the business performs after the sale. The two countries tax it at different times. In the UK, where the amount cannot be known at completion, the right to the earn-out is valued and taxed up front as part of the sale price. Each later payment is then a part disposal of that right. If the earn-out is paid in shares or loan notes of the buyer, the gain can be deferred instead.
In the US, the default is the instalment method. Gain is recognised as cash arrives, and part of each deferred payment is treated as interest. So the UK may tax the earn-out in the year of sale while the US taxes it over the next three years. Foreign tax credits can be carried back one year and forward ten, so UK tax paid early is usually usable against later US tax. The reverse is harder. You can elect out of the instalment method to pull the US gain into the year of sale when that gives a better match. That choice is made on the return for the year of sale and cannot be made later.
Share-for-share exchanges: UK rollover is not automatic in the US
A share-for-share exchange is a sale in which you receive shares in the buyer instead of cash. The UK normally treats the new shares as standing in the place of the old ones, with no gain until you sell them, provided the exchange is for genuine commercial reasons. Sellers usually obtain advance clearance from HMRC.
The US has no equivalent general rule. The exchange is tax-free only if it qualifies as a reorganisation under section 368, which has strict tests on the kind of consideration and the level of control, and section 367 adds conditions when foreign companies are involved. A deal built to UK rollover standards often fails them. The result is US tax now on the full gain, with no UK tax to credit. Years later the UK taxes the same gain when you sell the new shares, and by then the US has nothing left to tax. That is double tax on one gain, and it is fixed only by structuring before signing or by recognising the UK gain at the same time.
If a sale is on the horizon, tell us before heads of terms. The US analysis needs to be in the deal, not added to the return afterwards. We prepare the disposal on both returns, including the treaty relief and credit claims.
How does the UK tax a US LLC owned by a UK resident, and what is a Delaware flip?
HMRC generally treats a US LLC as a company, not a partnership, so a UK-resident member is taxed in the UK on distributions as dividends and may get no credit for the US tax paid on the LLC's profits. A Delaware flip is the opposite manoeuvre: putting a new US corporation on top of an existing UK company, usually because US investors ask for it.
The Anson point and HMRC's current position
In the US, an LLC with more than one member is taxed as a partnership by default. The members pay US tax on their share of profit each year, distributed or not. In Anson v HMRC in 2015, the UK Supreme Court held that Mr Anson was entitled to his share of a Delaware LLC's profits as they arose, on the facts found about that LLC's agreement. The US and the UK were therefore taxing the same income, and he could claim double tax relief.
HMRC has always read that decision narrowly. Its International Manual at INTM180050, last updated on 29 September 2026, says HMRC continues to believe that the profits of a Delaware LLC generally belong to the LLC, and that members are generally not entitled to them as they arise. Where the LLC is transparent in the US, HMRC's view is that there is then no double tax relief, because the same income is not taxed in both countries. The guidance adds that HMRC will consider an enquiry or discovery assessment where an individual has claimed relief on the Anson basis.
The practical result for a UK-resident member is harsh. The US taxes your share of profit each year at up to 37%. The UK taxes the cash you receive as a foreign dividend at up to 39.35%. On HMRC's view the two taxes are on different income, so neither credits the other. To claim Anson treatment you need evidence that your LLC agreement and state law give you the profits as they arise, and you should expect to defend it. Options include electing to treat the LLC as a corporation in the US so that both countries see a company, or using a limited partnership, which both treat as transparent. If you are a US citizen as well, the US foreign tax credit can absorb some of the UK tax on distributions.
Delaware flips
A Delaware flip is a reorganisation in which shareholders of a UK company exchange their shares for shares in a new Delaware corporation, which becomes the parent. In the UK it is a share-for-share exchange, and holders of EIS and SEIS shares need the reliefs to carry across, which they can under specific rules if the conditions are met and clearance is obtained. In the US the exchange is normally a tax-free contribution under section 351.
For a US founder the flip changes three things. The UK company becomes a CFC of a US corporation, so tested income is taxed at the corporate level at 12.6% with credits, not on your own return. Your new shares may be QSBS, but the five-year clock starts at the flip and the exclusion covers only growth after it. And the US parent must be kept out of UK tax residence, which turns on where its board really makes decisions. Flip early or not at all; the tax cost rises with the valuation. Our guide to US-UK business expansion covers the company-level steps.
How is carried interest taxed for a US person in the UK?
From 6 April 2026 the UK taxes carried interest as trading income, with only 72.5% of qualifying carried interest taxable, giving a top effective rate of about 34.1% including National Insurance. The US taxes the same carry as capital gain at up to 20% plus 3.8% if the fund held the assets for more than three years, and as short-term gain at up to 37% plus 3.8% if not. The two countries now disagree on its character, and often on its timing.
The UK regime year by year
Carried interest is the share of a fund's profits paid to its managers once investors have had their capital and an agreed return back. The UK has changed its treatment twice in two years.
| UK tax year | Treatment | Top rate |
|---|---|---|
| Up to 2024-25 | Capital Gains Tax at special carried interest rates | 28% |
| 2025-26 (interim year) | Capital Gains Tax at a single rate | 32% |
| 2026-27 onwards | Trading income: Income Tax and Class 4 National Insurance on 72.5% of qualifying carried interest | About 34.1% (47% on 72.5%) |
The new rules are in the Finance Act 2026 and described in HMRC's policy paper on the revised tax regime for carried interest. Carried interest is qualifying when the fund's average holding period for its investments is 40 months or more. Between 36 and 40 months a sliding proportion qualifies. Below 36 months none does, and the whole amount is taxed as trading income at up to 47%. Carry held by employees is now inside the holding period test, having previously been outside it.
The charge applies if you are UK resident, or if you are not but the carry relates to investment management services you performed in the UK. For non-residents the legislation limits the UK's reach: UK services before 30 October 2024 are ignored, a tax year with fewer than 60 UK workdays is ignored, and carry received more than three full tax years after you last met either test falls out.
The US side: section 1061 and the three-year holding period
Section 1061 is the US rule that treats gain from a carried interest as short-term unless the asset sold was held for more than three years. It is set out in section 1061 of the Internal Revenue Code. The test is applied asset by asset, at the level of whoever sold the asset. A fund can have an average holding period over 40 months and still sell individual investments inside three years.
So the two tests diverge. The UK asks about the whole fund's average. The US asks about each sale. Carry can be qualifying in the UK at 34.1% and short-term in the US at 37%, or long-term in the US at 20% and non-qualifying in the UK at 47%.
Where double tax comes from
Three mismatches cause it.
- Timing. The US taxes you when the fund allocates gain to you on Schedule K-1, even if the cash is held back in escrow or subject to clawback. The UK taxes carried interest when it arises to you, broadly when you receive it or can direct it. A 2026 US allocation paid out in May 2027 is taxed by the UK in 2027-28.
- Tax years. The US year is the calendar year. The UK year runs from 6 April to 5 April. UK tax for 2026-27 is not finally settled until 31 January 2028, well after the US return for 2026 is due.
- Character. The UK sees trading income. The US sees capital gain, and sorts foreign tax credits into separate baskets by type of income.
Treaty relief and foreign tax credit baskets
For a US citizen resident in the UK, the treaty generally gives the UK the first right to tax, and the UK gives credit only for US tax the US could have charged a non-citizen. The US then credits the UK tax. Because gains of a US citizen can be US-source under domestic law, Article 24 of the treaty lets you treat the income as foreign-source so the credit is usable. Income re-sourced this way goes in its own basket on Form 1116, and the claim is disclosed on Form 8833.
The credit only works if UK tax and US tax meet in the same basket and within the carry-back and carry-forward window of one year back and ten forward. When the US taxes first and the UK taxes a year or two later, the UK tax can be carried back only one year. A three-year gap can leave US tax paid and UK credits stranded. We track carry by fund and by year on both returns so the credits line up, and elect to claim credits on the accrual basis where that closes the gap. Our treaty relief service covers the forms.
Even when everything matches, the 3.8% Net Investment Income Tax is added. On qualifying carry held more than three years, expect about 34.1% in the UK and 3.8% in the US: roughly 37.9% in total.
What else does a US fund manager or partner in a UK fund have to report?
Beyond the carry itself, a US fund manager in the UK has to deal with how the US classifies each UK entity, fee income taxed as trading profit in the UK, Schedules K-1 and K-3 from US funds, Form 8865 for foreign partnerships, PFIC elections for offshore fund vehicles and the Net Investment Income Tax. A US-UK tax accountant for fund managers earns their fee on these, because each is a place where one country's form depends on the other's facts.
UK LLPs and US partnership classification
A UK limited liability partnership is transparent for UK tax: each member is taxed on their share of profit as a self-employed person, unless the salaried member rules treat them as an employee. The US does not follow automatically. Under the US entity classification rules, a foreign entity in which every member has limited liability is a corporation by default. A UK LLP is exactly that.
Unless the LLP has filed Form 8832 electing partnership status, a US member may own shares in a foreign corporation without knowing it, with Form 5471 or PFIC consequences and no credit for UK tax on profits the US does not see as theirs. Most management LLPs with US members made the election at formation. Ask for a copy of the accepted election. If none exists, late relief is sometimes available.
Form 8865
Form 8865 is the return US persons file for interests in foreign partnerships, including a UK LLP that has elected partnership status and a UK or Channel Islands limited partnership. The IRS page for Form 8865 sets out four categories: controlling more than 50%, holding 10% or more while US persons control, contributing property, and acquiring or disposing of a reportable interest. The penalty for missing a Category 1 or 2 filing is $10,000 a year, with the same open-ended statute of limitations as Form 5471.
Management fees and disguised investment management fees
Your share of the management fee is ordinary income in both countries. In the UK it is trading profit of an LLP member, taxed at up to 47% with Class 4 National Insurance. In the US it is ordinary income at up to 37%, and UK tax usually covers it in full. The totalization agreement keeps you out of US self-employment tax if you have a certificate of coverage.
The disguised investment management fee rules are UK rules, in force since 6 April 2015, that tax as trading income any sum arising to a manager from a fund unless it is carried interest or a return on a genuine co-investment. They catch fee waivers, priority profit shares routed through partnerships and similar arrangements. A structure common in the US, where a manager swaps fee for an extra profit share taxed as capital gain, generally produces trading income in the UK. The US may still see capital gain, which sends the credit to the wrong basket.
Co-investment
Co-investment is money you invest in the fund on the same terms as outside investors. The UK excludes a genuine arm's length return on it from the carried interest rules, so it is taxed as what it is: gains at 18% or 24%, dividends or interest. The US likewise excludes a capital interest from section 1061, so gains on assets held for more than a year are long-term. Loans from the firm to fund your co-investment need care in both countries.
Receiving and reporting Schedules K-1 and K-3
Schedule K-1 is the form a US partnership issues to each partner showing their share of income, gains, deductions and credits. Schedule K-3 is its international companion, showing the source and foreign tax credit category of each item. Without the K-3 you cannot complete Form 1116 properly, and for a US person in the UK the Form 1116 is what prevents double tax.
Many funds do not send a K-3 unless a partner asks. The IRS allows a partnership to skip it in some cases unless a partner requests it by one month before the partnership return is due. Put the request in writing each January. A UK fund partnership with US partners may also provide K-1 style information so its US partners can file; ask for it in the side letter.
PFIC exposure in fund structures
A passive foreign investment company (PFIC) is a non-US company where 75% or more of the income is passive, or 50% or more of the assets produce passive income. Fund structures are full of them: offshore feeder companies, non-US holding companies under the fund, foreign portfolio companies with little revenue, and money market funds holding undrawn cash. Your share of a PFIC held through a partnership is treated as yours.
Without an election, gain and large distributions from a PFIC are spread over your holding period, taxed at the top rate for each year, with an interest charge. Two elections avoid that:
- Qualified electing fund (QEF). You include your share of the company's ordinary earnings and net capital gain each year. It needs a PFIC Annual Information Statement from the company, so it has to be negotiated with the fund.
- Mark-to-market. You include the annual change in value as ordinary income. It is only for stock that is regularly traded on a recognised exchange, so it rarely fits private fund holdings.
Each PFIC is reported on its own Form 8621 each year. Elections are best made in the first year you hold the company. Our PFIC reporting service prepares them.
The Net Investment Income Tax and why UK tax cannot be credited against it
The Net Investment Income Tax (NIIT) is a 3.8% US tax on investment income of individuals whose modified adjusted gross income exceeds $200,000 if single, $250,000 if married filing jointly or $125,000 if married filing separately, as the IRS explains on its NIIT page. Those thresholds are not indexed. Carry, co-investment gains, dividends and gains on selling a company are all usually within it.
The Internal Revenue Code allows foreign tax credits only against the regular income tax, not the NIIT, which sits in a different chapter. Taxpayers argued that tax treaties give a credit of their own. The Tax Court rejected that in Toulouse in 2021. The Court of Federal Claims then accepted it in Christensen in 2023, under the France treaty, and in Bruyea in 2024, under the Canada treaty. On 31 August 2026 the Court of Appeals for the Federal Circuit reversed both, holding that the treaty credit is subject to the limits of US law and cannot offset the NIIT.
The US-UK treaty uses similar wording, giving credit in accordance with and subject to the limitations of US law. As matters stand in October 2026, a US person in the UK should budget for the 3.8% as an extra tax. If you filed refund claims on the earlier decisions, they are unlikely to succeed unless a further appeal changes the result.
How are RSUs and stock options taxed across the US and UK?
RSUs are taxed as employment income when they vest in both the US and the UK, so credits usually match. Stock options are harder: each country has tax-favoured option plans the other does not recognise, so RSU and stock option cross-border tax turns on which plan you hold, where you worked between grant and vest, and when each country's charge falls.
When each award is taxed in each country
| Award | US tax | UK tax |
|---|---|---|
| RSUs | Ordinary income on the share value when shares are delivered at vest; capital gain after | Employment income at vest through PAYE, with National Insurance; Capital Gains Tax after |
| US non-qualified options (NSOs) | Ordinary income on the spread at exercise | Employment income on the spread at exercise |
| US incentive stock options (ISOs) | No regular tax at exercise, but the spread counts for alternative minimum tax; long-term gain at sale if held two years from grant and one from exercise | Not recognised. Employment income on the spread at exercise |
| US employee stock purchase plan (ESPP) | No tax at purchase under a section 423 plan; discount taxed as ordinary income at sale | Not recognised. Employment income on the discount at purchase |
| UK EMI options | Not recognised. Ordinary income on the spread at exercise | No income tax at exercise if granted at market value; Capital Gains Tax at sale, with Business Asset Disposal Relief possible |
| UK CSOP options | Not recognised. Ordinary income on the spread at exercise | No income tax if exercised three to ten years after grant; up to £60,000 of options |
| UK unapproved options | Ordinary income on the spread at exercise | Employment income on the spread at exercise |
| UK SAYE (Sharesave) | Not recognised. Ordinary income on the spread at exercise | No income tax at exercise; discount of up to 20%; savings of up to £500 a month |
HMRC summarises the UK plans in its guidance on tax and employee share schemes. For EMI options granted from 6 April 2026, the company limits rose to £120 million of gross assets and 500 employees.
The pattern in the table is the trap. A favoured plan defers or removes tax in its home country only. An ISO exercised by a UK resident is taxed in the UK at exercise and in the US at sale, perhaps years later, so the UK tax may fall outside the credit window. Many UK-resident holders sell ISO shares in the year of exercise so both countries tax the same income in the same year. An EMI option exercised by a US person is tax-free in the UK and fully taxable in the US, with no UK tax to credit. EMI and SAYE options granted at a discount can also fall foul of section 409A, discussed below.
Sourcing equity income when you move: grant-to-vest apportionment
Sourcing is the rule that decides which country an item of income comes from. For equity awards earned while working in more than one country, both the US and the UK split the income by workdays over the period it was earned. Under each country's domestic rules that period runs from grant to vest, for RSUs and options alike.
The treaty changes one thing. The diplomatic notes exchanged with the US-UK treaty say that, for share options, the country you do not live in may tax only the part of the gain that relates to the period between grant and exercise in which you worked there. HMRC's Employment Related Securities Manual at ERSM163120 explains this grant-to-exercise treaty rule and how it sits beside the UK's grant-to-vest rule. RSUs stay on grant to vest.
Take an example. Daniel, a US citizen, is granted RSUs on 1 January 2024 while working in New York. He moves to London on 1 January 2026 and the RSUs vest on 31 December 2027, worth £200,000. Half the vesting period was worked in each country. The UK taxes £100,000 as UK-source employment income. The US taxes all £200,000 because he is a citizen, treats half as foreign-source, and credits the UK tax against the US tax on that half. New York may tax the half earned there as well. The same split applies in reverse to someone leaving the UK.
Section 83(b) elections and the UK section 431 election
A section 83(b) election is a US election to be taxed on restricted shares when you receive them, at their value then, and not later when the restrictions lapse. It must be filed with the IRS within 30 days of receiving the shares. There is no extension. It applies to actual shares that are subject to vesting, including shares from early exercise of an option, and not to RSUs or unexercised options.
A section 431 election is the UK counterpart. Employee and employer jointly elect to ignore restrictions when valuing the shares for income tax, so that later growth falls within Capital Gains Tax. It must be signed within 14 days of acquiring the shares and is kept by the employer, not sent to HMRC.
A US founder or early employee receiving restricted shares in a UK company needs both. Making one without the other leaves one country taxing at acquisition and the other at vesting, on different values, with nothing to match.
What happens to your pay, pension and deferred compensation when you move between the US and UK?
When you move, each country keeps the right to tax pay earned while you worked there, even if it is paid after you leave, so equity and bonuses create trailing liabilities for years. Your employer's withholding in each country rarely matches the final split, and deferred pay and pension contributions follow separate rules that the treaty only partly aligns.
Trailing liabilities after moving
A trailing liability is tax owed to a country you have left on income earned while you worked there. If you leave the UK with unvested RSUs, the UK taxes the UK-workday share of each later vest, and your former UK employer must still operate PAYE on it. If you leave New York or California, the state taxes the share of later vests and exercises earned there. US citizens remain taxable in the US on everything, so the question for them is always which country and which state has the first claim.
Withholding, PAYE and tax equalisation
PAYE is the UK system under which employers deduct income tax and National Insurance from pay, including the value of shares that can readily be sold. A US parent's RSUs delivered to a UK employee go through UK payroll, usually by selling enough shares to cover the tax. Some employers pass the employer's National Insurance on equity to the employee by agreement. That amount is deductible for UK income tax, but it is a social security charge and gives no US foreign tax credit.
Withholding is often wrong for a mobile employee. US payroll may withhold on the whole vest while UK payroll withholds on the UK share, so tax is paid twice at source and recovered on the returns. The recovery can take over a year. Ask payroll to apply the workday split in real time where they can.
Tax equalisation is an employer policy under which an assignee pays roughly the tax they would have paid at home, and the employer pays the actual tax in both countries. The employer deducts a hypothetical tax from your pay and settles up after the returns are filed. Tax the employer pays for you is itself taxable pay, so it is grossed up. Your returns must still be right: the equalisation settlement is calculated from them.
Bonuses spanning a move
A bonus is sourced to the period it was earned in, not the day it is paid. A bonus for calendar 2026 paid in March 2027 to someone who moved to London on 1 July 2026 is roughly half UK-source and half US-source by workdays. The UK does not tax the part earned for duties performed abroad before you became resident. The US taxes all of it for a citizen, with a credit against the UK-source half. Keep a workday calendar for every year you hold unvested awards or deferred bonuses.
Deferred compensation: sections 409A and 457A
Section 409A is the US rule that sets strict conditions on when deferred compensation can be elected and paid. It is in section 409A of the Internal Revenue Code. If a plan fails, the deferred amount is taxed when it vests, with an additional 20% tax and interest. It applies to US taxpayers wherever they work, so a UK employer's plan can fail it without anyone noticing. Common failures are options granted below market value, deferred bonus plans that let you choose the payment date, and long-term cash plans with flexible payout terms. Pay received within two and a half months after the end of the year in which it vests is outside the rule.
Section 457A is narrower and harsher. It taxes deferred compensation from certain foreign entities, and from partnerships whose income is mostly allocated to foreign or tax-exempt partners, as soon as it vests. It mainly affects managers with deferred fees from offshore funds. A UK company that pays full UK corporation tax is generally outside it.
UK pension annual allowance against the US treaty treatment
The annual allowance is the UK limit on tax-relieved pension saving each year: £60,000 for 2026-27. It tapers for high earners. If your threshold income exceeds £200,000 and your adjusted income exceeds £260,000, the allowance falls by £1 for each £2 of adjusted income above £260,000, to a minimum of £10,000. HMRC's annual allowance guidance has the detail, and unused allowance from the previous three years can be carried forward. Contributions above the allowance are taxed at your marginal rate.
On the US side, the treaty lets a US citizen resident in the UK treat contributions to a UK workplace scheme much as contributions to a US plan, within US limits, and defers US tax on growth until you take benefits. A UK annual allowance charge is a UK tax on income the US has not taxed, so it generally produces no usable credit. The pensions service covers transfers and lump sums.
The UK regime for new arrivals from 6 April 2025
The foreign income and gains regime replaced the remittance basis on 6 April 2025. If you become UK resident after at least ten consecutive tax years of non-residence, you can claim relief from UK tax on foreign income and gains for your first four tax years, whether or not you bring the money to the UK. You claim it on your return for each year, and a claim costs you the personal allowance and the capital gains annual exempt amount for that year.
Overseas Workday Relief runs alongside. It exempts employment income for duties performed outside the UK during the same four years, up to the lower of 30% of your qualifying employment income or £300,000 a year, as HMRC's Overseas Workday Relief guidance explains. Equity income earned across those years can qualify when it vests later.
For a US citizen these reliefs do not make income tax-free. They remove the UK from the picture, leaving the US as the only country taxing the income. That is valuable where the US rate is lower, as on long-term gains and qualified dividends. It also removes the UK tax you would otherwise have credited, so the US return has to be reworked.
How does a UK-resident executive report a K-1 from a US partnership?
You report your share of the partnership's income on your US return from the Schedule K-1, file any state returns it triggers, and report the same income on your UK Self Assessment return for the UK tax year it falls in, claiming credit in whichever country has the secondary right to tax. US-UK tax returns for executives receiving K-1s from the US are mostly an exercise in timing, because the K-1 arrives after the UK deadline has passed.
What a K-1 is and why it arrives late
A Schedule K-1 is the statement a US partnership or LLC gives each partner showing their share of the entity's income for the year. You are taxed on that share whether or not cash was distributed. Executives receive K-1s as partners in US professional firms, as holders of profits interests in a US employer, and as investors in US funds.
A calendar-year partnership must file by 15 March and can extend to 15 September. Funds that invest in other funds wait for those K-1s first, so final K-1s in August or September are normal. A K-1 for calendar 2026 can arrive in September 2027. The UK return for 2025-26, which takes in the first months of 2026, was due on 31 January 2027, eight months earlier.
State filing, composite returns and withholding
A partnership doing business in a US state gives its partners income sourced to that state. As a non-resident partner you may owe a return in each state, sometimes ten or more for a national firm. Two mechanisms reduce the filings. A composite return is a single state return the partnership files for its non-resident partners, paying their tax at a flat rate. A pass-through entity tax is a tax the partnership itself elects to pay to the state, which lowers the income on your K-1.
Check what your K-1 package shows for each state: income, tax withheld or paid for you, and whether you were included in a composite return. The treaty covers only US federal income tax. The UK can still give credit for state income tax under its own unilateral relief rules, but whether an entity-level state tax qualifies is less certain, and we review that before claiming it.
Reporting the K-1 on a UK return
The UK taxes a resident partner on their share of a foreign partnership's profits, recomputed under UK tax rules and allocated to the UK tax year. For a trading or professional partnership, since 2024-25 that means apportioning its calendar-year results across two UK tax years. The 2026-27 UK return takes roughly three quarters of the 2026 result and a quarter of the 2027 result, and the 2027 K-1 will not exist when that return is due on 31 January 2028.
Which country credits the other depends on the income. For a UK resident who is not a US citizen, the US taxes income connected with the partnership's US business, and the UK gives credit for that US tax. A US citizen resident in the UK follows the treaty's ordering rules item by item. If the entity is a US LLC, remember HMRC's view from the earlier section: the UK may tax only distributions and deny credit for US tax on the profits.
An extension strategy for both returns
- January. Ask the partnership for an estimate of your K-1 income, the K-3 and a state schedule. File the UK return by 31 January using provisional figures, marked as provisional.
- April. Pay estimated US tax by 15 April, because interest runs from then even though Americans abroad have until 15 June to file. File Form 4868 to extend to 15 October.
- September. When the final K-1 arrives, complete the federal and state returns.
- October. File the US returns by 15 October. A further extension to 15 December is available on written request for taxpayers abroad.
- After filing. Amend the UK return with final figures. You have twelve months from the 31 January filing date to amend.
We prepare the US federal return and the UK Self Assessment return together, so the provisional UK figures and the final US figures are reconciled once, not explained to two firms.
What cross-border tax planning matters for high-net-worth US-UK families?
Cross-border tax planning for high net worth families with US and UK ties centres on five things: UK Inheritance Tax now following residence, the US-UK estate and gift tax treaty, gifts to a spouse who is not a US citizen, trust reporting, and holding investments that neither country penalises. Expatriation is the sixth, for those considering it. This section gives the essentials of each.
UK Inheritance Tax on a residence basis
From 6 April 2025, UK Inheritance Tax on non-UK assets depends on whether you are a long-term UK resident, not on domicile. You are a long-term UK resident once you have been UK tax resident for at least 10 of the previous 20 tax years. After you leave, the status continues for between three and ten years depending on how long you were resident, as HMRC's guidance on Inheritance Tax for long-term UK residents explains. Once it applies, your worldwide estate is within Inheritance Tax at 40% above the nil-rate band.
An American who has lived in the UK for ten years is therefore exposed to both UK Inheritance Tax and US estate tax on the same worldwide assets. The US estate tax exemption is $15 million per person for 2026 and is indexed after that. The UK nil-rate band is £325,000. For most such families, the UK is now the binding constraint.
The US-UK estate and gift tax treaty
The US and the UK have a separate estate and gift tax treaty, signed in 1978. It allocates taxing rights by domicile as the treaty defines it, with tie-breaker rules where both countries claim you, and gives credit so the same asset is not taxed in full twice. HMRC lists it with the income tax treaty on its UK-USA tax treaties page. How its domicile tests apply now that UK law uses residence is something to check case by case.
Gifts to a non-US spouse
Gifts between spouses who are both US citizens are free of US gift tax without limit. Gifts to a spouse who is not a US citizen are not. The annual exclusion for such gifts is $194,000 for 2026, against $19,000 for gifts to anyone else. Larger gifts use up your lifetime exemption and need a gift tax return on Form 709. On death, the unlimited marital deduction is available only through a qualified domestic trust. The UK has its own limit on the spouse exemption where the giver is a long-term resident and the recipient is not. Putting the family home into a non-US spouse's name is a gift for these purposes.
Trusts and Forms 3520 and 3520-A
A US person who creates, funds or receives a distribution from a non-US trust must report it on Form 3520, and a foreign trust with a US owner files Form 3520-A. Penalties start at the greater of $10,000 or a percentage of the amount involved. UK family trusts, will trusts and some employee benefit trusts are all foreign trusts in US terms. A US beneficiary of a UK trust that has accumulated income faces a punitive US charge on later distributions. Check the US position before a UK solicitor drafts anything.
Investing without PFICs
UK-domiciled funds, including unit trusts, OEICs, investment trusts and most exchange-traded funds listed in London, are PFICs for a US person. US-domiciled funds avoid that, but a UK resident who holds a non-reporting offshore fund pays income tax, not Capital Gains Tax, on the gain. The workable answers are direct holdings of shares and bonds, or US funds that have UK reporting fund status. This is the same PFIC regime described for fund structures above, and our PFIC reporting service deals with existing holdings.
Expatriation
Giving up US citizenship or a long-held Green Card ends US taxation of future worldwide income, but it can trigger an exit tax. You are a covered expatriate if your net worth is $2 million or more, or your average annual US income tax for the previous five years exceeds $211,000 for 2026, or you cannot certify five years of full US tax compliance. A covered expatriate is taxed as if they had sold everything the day before, with the first $910,000 of gain excluded for 2026. Deferred compensation, unvested equity and pensions have their own rules. Founders and fund managers should model this before a liquidity event, not after. See our expatriation service and the wider cross-border tax planning page.
How does US UK Tax Experts work with founders, fund managers and executives?
US UK Tax Experts prepares your US return and your UK return from one file, with the company, partnership and equity reporting that goes with them, so each figure is reported consistently in both countries and each credit is claimed against the right income. We start from the documents, tell you what the filings involve, and raise the choices that need a decision before a deadline closes them.
What we do for each group
- Founders. Form 5471 or Form 8858 with your Form 1040, the tested income and high-tax calculations, section 962 elections, and your UK Self Assessment return with salary, dividends and any disposal. We work from your UK accountant's company accounts and corporation tax return; you do not need to replace them.
- Fund managers. Carry tracked by fund and tax year in both countries, Schedules K-1 and K-3, Form 8865, Form 8621 for each PFIC, and the foreign tax credit and treaty claims that connect the US and UK figures.
- Executives. Equity income apportioned by workdays, PAYE and US withholding reconciled, K-1 income and state returns, pension reporting and the arrivals reliefs in your first four UK years.
If earlier years were missed or filed without the international forms, we deal with that first. Most people in that position qualify for the streamlined procedures, and it is better to come forward than to be asked.
What to bring to a first conversation
- Your last two US returns and UK returns, as filed, or a note that none were filed.
- For a company: the latest accounts, corporation tax computation, share register and any US elections made.
- For a fund interest: the partnership or LLP agreement, your latest K-1 and K-3 or UK partnership statement, and carry and co-investment statements by fund.
- For equity pay: grant agreements, vesting and exercise statements, payslips or P60s and Forms W-2, and a calendar of the days you worked in each country since the earliest unvested grant.
- Your residence history: dates of arrival and departure, visa or Green Card dates, and any US state you may still be resident in.
- Anything planned in the next 18 months: a sale, a funding round, a move, a new fund, a gift or a change of citizenship.
The last item matters most. Almost every problem on this page is cheaper to prevent than to repair, and many elections can only be made at the start.
Contact is by email. Write to hello@usuktaxexperts.com or use the contact page, and we reply within one working day. Tell us which of the three groups you are in and what is coming up, and we will tell you what the returns involve.
