In the uncertain economic environment post Brexit, US citizens
and green card holders living in Britain may have questions
regarding how their US tax and reporting obligations may have
changed. Will I now be subject to tax in both the US and the UK? Is
my UK account now safe from information sharing with the US?
Rest assured that Britain has its own income tax treaty with the
United States regarding double taxation. Accordingly, post-Brexit,
US citizens and green card holders living in Britain will continue
to enjoy largely applicable relief against double taxation (but
keep watching out on your retirement accounts!).
Britain directly participates in global information sharing
regimes (such as the Foreign Account Tax Compliance Act (FATCA)
enacted by the United States and the OECD's Common Reporting
Standard (CRS)). Accordingly, the US Department of Justice and the
Internal Revenue Service will continue to receive annual reports on
British accounts held by US citizens and green card holders.
British-based US citizens and green card holders should review
their US tax and reporting obligations to make sure that there are
no adverse surprises awaiting them once their information is shared
with the United States. Click here for more information on those
As Brexit does not change the obligation of US citizens and
green card holders to report and pay taxes on their worldwide
income, to report certain foreign assets and to report their
foreign financial accounts annually to the US government on an FBAR, penalties for a misstep remain
potentially draconian. For more details about the streamlined
program available to help certain US taxpayers living abroad with
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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