Treaty guides
United Kingdom to United StatesMoving from the UK to the US: a tax planning map
A UK-to-US move is not one tax event. It can change your status under UK residence rules, US federal residence rules, a state's rules, and separate reporting regimes on different dates, so build the filing map before trying to calculate an outcome.
Treat the move as several separate questions
Start with UK domestic residence for the UK tax year, US federal status for the calendar year, and any relevant state or city status. A conclusion in one layer does not automatically settle another, and immigration status is not a substitute for the tax tests.
Map the periods before the income
Record the move, home, employment, and travel milestones against both filing calendars. Then place wages, investments, property, and other items into the periods in which each jurisdiction may ask about them, without assuming the same allocation rule applies twice.
Keep filing and reporting questions separate
An income-tax return, a state return, an FBAR, and Form 8938 are different obligations with different tests and filing channels. A checklist should investigate each one independently and should label unsupported or unresolved items rather than collapsing them into a single yes-or-no result.
Coordinate after the domestic positions are identified
Treaty positions and foreign-tax relief can depend on residence, source, timing, and the legal tax actually due. Preserve both domestic analyses and their evidence before considering relief; do not begin with the assumption that one country simply cancels the other. One exception to this order matters: if both countries treat you as resident for the same period under their own rules, the treaty residence tie-breaker can decide which country treats you as resident for treaty purposes, and that can change which return position applies. That question belongs with the residence analysis, before any relief is calculated.
Worked example
Synthetic example: Maya leaves Manchester for New York in September, starts a US job, keeps a UK savings account, and receives a UK bonus after moving.
- Place the move and work dates on both the UK tax-year and US calendar-year timelines.
- Investigate UK residence and split-year conditions, US federal status, and New York status independently.
- Classify the later bonus and foreign accounts only after the relevant period and reporting tests are identified.
The example identifies questions and evidence only; it does not decide Maya's residence, source, relief, forms, or Treaty product coverage.
Five-layer move map
- UK residence and possible split-year layer
- US federal residence or dual-status layer
- State and local residence and source layer
- Treaty and double-tax-relief coordination layer
- Foreign account and asset reporting layer
Sources
- RDR3: Statutory Residence Test notes (HMRC; checked 2026-10-08)
- Determining an individual's tax residency status (IRS; checked 2026-10-08)
- Tax information and responsibilities for new immigrants to the United States (IRS; checked 2026-10-08)