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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

General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.

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Tell us your situation

Where you live, which years are involved, what has been filed, and every source of income in each country. We reply by email within two working days with what is needed and a written fee. No free consultations, and no work starts before you have the quote.