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Moving

Five things to do before you move, and one thing not to

Almost everything that saves tax on a transatlantic move has to happen before you land. A short list of what to do while the planning window is still open.

4 min read

  • Relocation
  • Planning
  • Property
  • Funds

The single most useful thing to understand about a transatlantic move is that the tax planning window closes on arrival. The same steps are mostly still available afterwards — at a worse price, and occasionally not at all. Here is what to use the window for.

1. Find out when residence actually starts

Not when you arrive. When the rules say you become resident, which in the US can be earlier than you expect and in the UK depends on a test with several moving parts. Everything else on this list depends on knowing that date, so establish it first.

2. Look at every fund you hold

If you are moving to the US, non-US funds — including those inside an ISA — become a reporting burden and a tax penalty the moment you are resident. Realising them before that date is often far cheaper than carrying them across. If you are moving to the UK, the question is different but still worth asking.

3. Decide what happens to the house

Sell, let, or keep empty — each has a different answer in each direction, and the reliefs for a main residence do not match across the two countries. A sale that is exempt at home can be taxable in the new country if it completes a few weeks too late.

4. Read your pension paperwork

Not to act on, necessarily, but to understand what you hold, because the treatment of contributions, growth and eventual drawdown differs between the systems and some positions need to be taken from the first year. Transfers in particular are worth pausing on.

5. Tell the country you are leaving

Leaving physically and leaving for tax are not the same thing. Both countries have procedures for notifying departure, and both have ways of deciding you have not really left. A state in the US may have a view of its own. Close the record properly.

And the thing not to do

Do not assume the treaty handles it. The treaty relieves double taxation in many situations. It does not remove either filing obligation, it does not bind US states, and for US citizens it gives back less than it appears to. Plan as though both countries will want a return, because both countries will.

General commentary, not advice for your circumstances. Cross-border tax turns on detail, and the right answer for someone in an apparently similar position may not be the right answer for you.

Frequently asked

How far in advance should I plan a transatlantic move?

The tax year before the move, where possible. Even a few weeks of notice can change which year a disposal falls into; a few months opens up far more options.

Should I sell my home before I move?

It depends on the direction and your circumstances. The reliefs for a main residence differ between the two countries, so a sale that is exempt at home can be taxable abroad if it completes a few weeks too late.

Does the treaty mean I will only file in one country?

No. The treaty relieves double taxation in many cases but does not remove either filing obligation, and it does not bind US states. Plan for two returns, because that is what you will file.

What is the single most useful thing to do first?

Establish the date residence actually starts in the new country. Everything else on the list depends on knowing that date, and it is rarely the day you arrive.

If any of this sounds like your situation, it is worth a conversation before it becomes a filing.

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