US & UK tax, handled together

Yes. US citizens and Green Card holders file on their worldwide income every year, whatever country they live in and whether or not any tax ends up being due.

In practice most people in this position owe little or nothing to the IRS once the Foreign Earned Income Exclusion or foreign tax credits are applied. That is a relief on the bill, not on the filing - the return still has to go in, and the reliefs only apply if you claim them.

FBAR is a report of your foreign bank and financial accounts, filed with FinCEN rather than the IRS. It is triggered when the combined high balance of all your non-US accounts passes $10,000 at any point in the year.

Two things catch people out. It is aggregate, so several small accounts can cross the line together. And it counts the highest balance during the year, not the closing balance - money that passed through briefly still counts.

It is a disclosure form, not a tax charge. Nothing is owed on the accounts themselves, but the penalties for not reporting them are steep.

An ISA is tax-free in the UK. The IRS does not recognise the wrapper at all, so the income and gains inside it are simply taxable to you as a US person.

The larger issue is that most UK funds - unit trusts, OEICs, investment trusts, and the funds inside an ISA - are PFICs under US rules. PFIC treatment is punitive by default and the reporting is heavy.

There are elections that improve the outcome, but they generally have to be made in the right year. This is the single most common area where we find people have quietly built up a problem.

It is the route back to compliance for people whose failure to file was non-wilful - typically someone who simply did not know the obligation existed.

The submission covers 3 years of returns and 6 years of FBARs, together with a signed certification explaining why the omission was not deliberate. Where it is accepted, the usual failure-to-file and FBAR penalties fall away.

Eligibility is not automatic and the certification carries real weight, so it is worth assessing properly before filing anything.

The US-UK double tax treaty allocates taxing rights between the two countries and sets out which one has the primary claim on each type of income.

In most cases relief comes through foreign tax credits: tax paid in one country is credited against the liability in the other. For pensions, dividends and certain gains, specific treaty articles override the default treatment.

None of this happens automatically. Relief has to be claimed correctly, in the right country, in the right year - and the order the two returns are prepared in genuinely affects the result.

It depends on the scheme and on what you are doing with it. Employer contributions, personal contributions, growth inside the fund, and eventual withdrawals are each looked at separately, and the US does not necessarily follow the UK treatment on any of them.

The treaty helps considerably here, and a UK pension usually can be held without a bad US outcome. What causes damage is assuming the UK tax-free treatment carries over automatically - particularly around a tax-free lump sum, or drawing on the pension while resident in the US.

Not everyone does. If all your UK income is taxed through PAYE and there is nothing else going on, you may have no filing requirement at all.

You will generally need to file if you have self-employment or rental income, untaxed foreign income, capital gains to report, higher-rate income, or if HMRC has issued you a notice to file.

Where a US return is also in play we prepare both together, because figures and timing on one side feed directly into the credits claimable on the other.

It is a very common position and, in the great majority of cases, a fixable one. What matters is that the disclosure is made on your terms rather than after the authorities raise it.

We start by working out how far back the exposure actually runs and whether you qualify for Streamlined or another relief route. Often the reconstruction turns out narrower than people fear, and the eventual tax due is modest once credits are applied.

Where the same history spans both the IRS and HMRC, we deal with both rather than fixing one and leaving the other open.

We quote a fixed fee for the work in front of us, agreed before anything begins. No hourly billing, and never a percentage of tax saved.

The figure depends on genuine complexity: how many jurisdictions are involved, whether there are funds, pensions, property or a business in the picture, and how many years need bringing current.

An initial scoping call is free. You will have the scope and the number in writing before you decide to go ahead.