Dual US–UK citizens
Two passports, two returns, one coordinated position.
Dual citizens file in the US every year and in the UK when resident with reportable income. The treaty's saving clause means the US keeps the right to tax its citizens, so relief comes mainly through foreign tax credits rather than exemption.
Typical situations
- Living in the UK with UK income
- Living in the US with UK pensions, property or investments
- Moving between the two countries
What is normally filed
- Form 1040 with Form 1116
- Foreign Tax Credit for UK tax on the same income.
- UK Self Assessment
- Where UK resident with reportable income, including US-source income with Foreign Tax Credit Relief.
- FBAR and Form 8938
- For non-US accounts and assets, wherever you live.
What catches people out
- Pension contributions, growth and lump sums are each treated under specific treaty articles.
- UK CGT at 18%/24% can leave residual US tax on gains.
- Timing differences between the UK tax year and US calendar year need a consistent apportionment method.
FAQ
Questions we are asked
Does the treaty exempt me from US tax because I live in the UK?
No. The saving clause lets the US tax its citizens as if the treaty did not exist, with specific exceptions (pensions and Social Security among them). Relief comes through the Foreign Tax Credit.
Written by the US UK Expat Tax advisory team. Last reviewed 7 November 2026
Primary sources checked
General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.
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