Who we help
Landlords & property owners
Property is reportable in the country it sits in and in the country you live in, on two different sets of rules.
The same building, computed twice, rarely the same number.
Rental income is taxable where the property is and, for US taxpayers, again on the US return. Both are due, and the credits between them depend on getting the computations aligned.
Depreciation is the usual divergence: mandatory in the US, absent in the UK, and it follows you to the eventual sale.
What we handle
01
Rental income
Two computations from one property, with allowable expenses that do not match.
02
Depreciation
US rules require it whether or not you claim it, and it is recaptured on sale. Non-US property runs on a longer life.
03
Selling
Gains are calculated differently, and the US main-home exclusion and UK private residence relief do not cover the same ground.
04
Non-resident schemes
The UK Non-Resident Landlord Scheme, and US withholding under FIRPTA when a non-resident sells.
Why us
Depreciation you did not claim is still recaptured
US rules recapture depreciation you were allowed to take, whether or not you took it. Landlords who never claimed it are still taxed as though they had.
It is worth checking early, because the correction is easier than the surprise at completion.
Frequently asked
I let a UK flat and live in the US. Where do I report it?
Both. UK Self Assessment on the UK-source rent, and your US return on worldwide income, with a foreign tax credit for the UK tax paid.
Is my main home exempt when I sell?
Not necessarily in both countries. UK private residence relief and the US Section 121 exclusion have different tests, limits and periods, and a gain sheltered in one can still be taxable in the other.
What is the Non-Resident Landlord Scheme?
A UK scheme under which letting agents or tenants withhold basic-rate tax from rent paid to a landlord abroad, unless HMRC approves receipt of rent gross. Approval is worth obtaining.
Can I claim mortgage interest?
Differently in each country. UK relief for individuals is now a basic-rate tax reducer rather than a deduction, while the US position depends on the property's use. The computations diverge accordingly.
What is FIRPTA?
US withholding on the sale of US real property by a non-resident, typically a percentage of the gross price withheld at closing. It is a payment on account, and often more than the tax due.
Does currency movement affect my gain?
Yes, and it surprises people. The US computes gain in dollars, so exchange-rate movement between purchase and sale can create a taxable gain even where the property did not rise in local terms.
What if I rent out a room in my own home?
The UK Rent a Room scheme has no US equivalent. Income exempt under it is generally still reportable to the IRS.
Property is reportable in the country it sits in and in the country you live in, on two different sets of rules.
Talk it through
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