Who we help
Dual citizens
Holding both passports means both tax systems have a permanent claim on you, wherever you actually live.
Two citizenships, two filing obligations, no expiry date.
US citizenship carries a filing obligation for life, regardless of where you were born, where you live, or whether you have ever used the passport.
Combined with UK residence or UK-source income, that means running two systems in parallel indefinitely, and keeping the positions consistent across decades rather than years.
What we handle
01
Lifetime compliance
Annual returns in both countries, with positions that hold up when reviewed years later.
02
Investments that clash
Products that are efficient in one country are frequently penalised in the other. ISAs and non-US funds are the usual example.
03
Estate and inheritance
The US estate tax and UK inheritance tax use different bases, thresholds and reliefs, and the interaction rewards planning early.
04
Passing it on
US citizenship can transmit to children born abroad, along with the obligations. Better understood before they inherit the problem.
Why us
Decisions that compound
Dual citizens accumulate positions — on pensions, on funds, on residence — and the cost of an inconsistent one grows with every year it is repeated.
We would rather set the treatment deliberately once than unwind a decade of it later.
Frequently asked
I have never lived in the US. Do I still have to file?
If you are a US citizen, yes. Filing is based on citizenship rather than residence, and having been born there is enough to create it even if you left as an infant.
Can I give up US citizenship to stop filing?
It is possible, but renouncing is a formal process with its own tax consequences, potentially including the exit tax. It is a decision to model properly, not a shortcut.
Does the treaty stop me being taxed twice?
Generally yes in substance, through foreign tax credits and the treaty's allocation rules. It does not reduce the number of returns you file, which is the part people hope it will fix.
Which country taxes my investment income?
Both will look at it. Which one gets the primary claim depends on the type of income and where you are resident, and the other normally gives credit. Non-US funds are the common complication.
Can my children avoid inheriting this?
US citizenship transmits by birth in certain circumstances rather than by choice. Whether it has passed to a child is a question of fact worth establishing early, before it compounds.
Should I keep my investments in one country?
Usually it simplifies matters, and which country depends on where you expect to be long term. The costly pattern is holding products each system penalises.
What happens when I die?
US estate tax and UK inheritance tax can both reach the same estate, on different thresholds and reliefs. There is treaty relief, but it needs planning rather than discovering.
Holding both passports means both tax systems have a permanent claim on you, wherever you actually live.
Talk it through
Tell us what you are trying to solve and we will put the right specialist on the call.
Client enquiries
US–UK tax team
Others we work with
Everyone we help
Stay informed with our latest publications and insights.
Latest
Read our insights
Specialists who work in both tax systems every day, not one with a view on the other.