Relocating from the US to the UK?

Get move-ready with our FAQs on tax, immigration, property and more

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Moving country is no small undertaking, and we frequently help US citizens and UK expats (living in the US) who are considering the move across the Atlantic to the UK, assisting with the wide range of cross-border issues that arise from relocating. Because of the recent changes to the UK’s non-dom regime, many are particularly eager to understand their potential exposure to UK tax under the new rules.

There are also plenty more planning points to consider: what are your visa options? How should you purchase a residential property? Will your US pre-nup still be effective?

Our US-UK specialists answer your questions and highlight the need-to-know points in our ‘US to UK’ FAQs.

Tax

Since 6 April 2025, the UK has a new tax relief system called the ‘foreign income and gains’ (FIG) regime. This is available if you have not been UK resident in any of the previous 10 UK tax years. Under the FIG regime you can claim relief from UK tax on most forms of non-UK income and gains during your first four tax years of UK residence. Notably, the relief applies whether or not the non-UK income or gains are brought to or used in the UK.

The claim is made in your UK tax return within 12 months of the usual filing deadline (the 31 January following the end of the tax year). For example, relief for income or gains realised in the 2025/26 tax year must be claimed by 31 January 2028. You’ll need to declare the amount and type of foreign income or gains that the relief applies to.

After four years of UK residence you will no longer qualify for the FIG regime and will be subject to UK tax on your worldwide income and gains.

The remittance basis of taxation, which allowed non-domiciled individuals to be taxed on non-UK income and gains only if remitted to the UK, is no longer available. However, the previous remittance rules still apply to non-UK income and gains that arose before 6 April 2025 if you were UK resident and a remittance basis user. Therefore, if you previously claimed the remittance basis you should take care to avoid accidentally triggering a taxable remittance.

To find out more read our article on Moving to the UK: key considerations for US citizens. 

Yes, it is important to get UK advice before moving. For example, if you are the trustee of a trust or a director of a company, we would want to ensure that you do not inadvertently make those structures UK resident and subject to UK taxes.

While the US usually treats LLCs as partnerships and transparent for US income tax purposes, the default position in the UK is different because HM Revenue & Customs treat LLCs as companies and opaque for UK tax purposes. This can result in a mismatch in tax treatment with members being subject to US tax on their share of the LLC’s underlying profits but being liable to UK tax on distributions from the LLC as dividend income. The options for mitigating this exposure should be considered.

To find out more read our article: Anson Revisited: What does HMRC’s updated guidance mean for UK resident members of US LLCs?

Exposure to IHT is now based on whether you are a ‘long-term UK resident’ (LTR). You will become an LTR if you have been UK resident in 10 or more of the preceding 20 tax years (i.e. from the beginning of your 11th year of residence). If you are an LTR, you (or your estate) will be exposed to IHT on your worldwide assets.

Once an LTR, your exposure to IHT will remain until you have ceased being UK resident for a certain period: aside from some transitional rules, generally you would need to be non-UK resident for a minimum of three years but up to 10 years if you were UK resident for at least 20 years.

If you are not LTR, you will only be exposed to IHT on your UK assets and non-UK situs assets that derive their value directly or indirectly from UK residential property. In certain circumstances, the US-UK estate and gift tax treaty can offer protections against inheritance tax (see below).

We explore the impact of changes to UK IHT on UK resident Americans and the use of family limited partnerships (FLPs) as an alternative vehicle for IHT planning in this article.

As long as you have been non-UK tax resident for 10 consecutive UK tax years, you can take advantage of the FIG regime.

Similarly, provided you were non-UK resident for 10 consecutive tax years out of the previous 19 tax years, you should not be an LTR when you first move to the UK and only your UK assets (and those deriving their value from UK residential property) will be subject to IHT.

Therefore, if you’re a UK expat, you can also benefit from the new rules and there are planning opportunities available if you are considering a return to the UK.

Trusts

In short, under the new IHT rules, the liability of a trust to UK inheritance tax broadly depends on (i) whether the trustee directly holds any UK situs assets or any assets deriving their value from UK residential property, and (ii) the LTR status of the settlor. For example, a trust becomes liable to IHT on its worldwide assets if the settlor is alive and becomes an LTR.

However, the US-UK estate and gift tax treaty provides that no IHT is due on assets held in a trust (other than UK real estate and business property of a permanent establishment) settled by an individual who is domiciled in the US and not a UK citizen. Therefore, provided you create a trust holding non-UK situs assets (and assets that are not treated as having a UK situs) before becoming an LTR, those assets should be shielded from IHT even if you later become an LTR.

You will be taxed in the UK if you receive benefits from the trust but otherwise you should not be chargeable to UK tax on income and gains arising within the trust. As a non-UK resident the settlor should not be chargeable to UK tax on the trust’s income and gains for as long as they remain non-resident.

In addition, provided the settlor does not become UK resident and the trust does not hold UK situs assets (or those deriving their value from UK residential property), the trust should not be exposed to IHT.

How we can help

Our US/UK private client specialists are experienced in advising on US/UK cross-border matters, including personal tax, trust and estate planning. With a strong understanding of US tax issues and how they interact with UK taxation, we can help you structure your move to take advantage of available reliefs and ensure your affairs are optimised for both sides of the Atlantic.

Immigration

There are various immigration options for moving to the UK. The option that suits you best will mostly depend on your objectives and reason for relocating. Particular options are available if you:

  • have lived in the UK previously, it may be possible to obtain a Returning Resident’s visa;
  • are married to a UK citizen and you move to the UK, it should be possible for you to obtain a Spouse visa;
  • have an EU passport and have historically lived in the UK, you may still be able to apply for settled status on a discretionary basis.

Otherwise, we can explore your eligibility for one of the other visa options. For example, you might be able to apply for a Skilled Worker visa (where a UK employer sponsors a foreign skilled worker) or the Innovator Founder visa (for experienced businesspersons establishing a business). Our specialist Immigration team can advise on your circumstances.

How we can help

Our dedicated immigration team can guide you through the process and advise on the most suitable route based on your personal circumstances.

Buying a home

Purchasing a residential property in England & Wales involves the following steps:

  1. Deciding to buy
    You will need to decide how to fund and structure your purchase, and in whose name to register the property. You should also ensure you have cash available to fund the deposit, which will be due on exchange of contracts as well as any Stamp Duty Land Tax (SDLT) payable. The SDLT rate will depend on a range of factors including price, residence and whether you own another residential property anywhere in the world.
  2. Choosing a property
    Once you have found a property you like, you make an offer through the estate agent and, if accepted, the agent will circulate a memorandum of sale to your solicitors. The memorandum of sale sets out the property details and the terms of the offer (which are not legally binding until contracts are exchanged).
  3. Investigating the Title to the property
    Your solicitor will review all documentation sent by the seller’s solicitor, including the title to the property, the lease (if relevant), standard replies to enquiries and any other supporting documents. Your solicitor will also submit ‘searches’ to various public authorities. It is also recommended that you instruct a surveyor to inspect the property and check for any structural defects.
  4. Exchange of contracts
    If you wish to proceed, you will be asked to sign the contract, send the deposit to your solicitor, and agree a completion date with the seller.
  5. Completion
    On the day of completion, your solicitor will send the completion funds to the seller’s solicitors and upon receipt, the seller will date the transfer and confirm completion has taken place. The keys will then be released by the agents and you will be the proud owner of your new property.

Find out more about buying and owning a home in England & Wales by reading our residential property FAQs.

If you buy a UK property, this will be a UK asset that is subject to IHT (it is no longer possible to prevent this by purchasing it through a non-UK company). If you are married and your spouse is not a US person, it is beneficial from a tax perspective for your main home to be purchased solely by the non-US spouse. This should enable you to benefit from private residence relief, which often means the property will not be subject to UK capital gains tax (the US relief for principal homes is much less generous).

There may be other tax considerations if your non-US spouse does not have the funds in their own name to buy the property.

If you buy a UK property, we recommend that you put in place a UK will and consider obtaining life insurance to cover the IHT exposure.

How we can help

Our residential property team can guide you through the process of buying property in the UK and help you secure your dream home.

Couples and families

This will depend on the circumstances when it was signed and at the time of divorce. In particular, the English courts will consider whether the terms are fair from an English legal perspective, which differs in various respects from many US states. This will be the case even if the agreement states it should be governed by US law and would have been binding in the relevant US state.

We would recommend having your nuptial agreement reviewed from an English law perspective before or as soon as possible after you move here. You may wish to consider entering into a post-nuptial agreement to bring your nuptial agreement into closer alignment with English law.

If you do not have a pre-nup, it can be prudent to enter into a post-nup as part of your move, particularly as the finances between a married couple often change as part of a relocation.

Find out more about the use of nuptial agreements when you have connections to the US and UK in this article.

How we can help

Our family team have specialist expertise in trans-Atlantic nuptial agreements and work with US lawyers to ensure you remain protected in both jurisdictions.

Wills and mental capacity

When moving between countries it is always sensible to review your estate plan and consider whether your Will needs updating; for example, you might be moving your assets and purchasing a property to live in. While a US Will can be admitted to probate in the UK, there are additional administrative hurdles that the executors would need to cross, which means that the process can take longer than if you had an English Will dealing with your UK assets. Therefore, we often recommend that you have an English Will to streamline the administration of your UK assets.

No, we recommend you put in place UK lasting powers of attorneys (LPAs). These allow you to appoint one or more persons (known as “attorneys”) to make decisions on your behalf if you become incapable of doing so.

There are two types that deal with your:

  1. financial and property affairs, and
  2. health and welfare.

Your financial and property affairs LPA can be registered so that your attorney(s) can act during your lifetime even if you have capacity – for example, your attorney(s) can deal with your bank account/ investments if you are unavailable (say if you are travelling).

How we can help

Our US/UK private client team can help you put plans in place to protect you and your family, should something happen to you in the future.

Your guide to US-UK cross-border planning

If you have connections to the US and the UK you’ll need to navigate between two very different regimes. Understand the issues, avoid the traps and discover ways to plan ahead.

Visit our Navigating the Atlantic hub

Get in touch

Have further questions about relocating from the US to the UK, or need advice tailored to your specific circumstances? Our specialist UK-US team is here to help. Submit a question via this form or get in touch with a member of our team for personalised advice and expert support every step of the way.

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Relocating from US to UK