Stocks & Shares ISA
Holdings inside an ISA are still reportable to the IRS — and Irish-domiciled UCITS inside it are PFICs. We classify every position.
Convention 2001 · IRS × HMRC
The US–UK tax treaty, for Americans in the UK.
Your ISA isn't tax-free to the IRS.
We prepare a Form 8621 worksheet for each and reconcile against your SA100.
UK-US Convention 2001 plus the 2002 Protocol covers dividends, interest, pensions, and gains. ISAs and UK pension wrappers get explicit attention because HMRC's tax-free status doesn't carry over.
Free PFIC scan · Pay to generate the draft package · Mapped Forms 8621 / 8938 / FBAR / 1116 / 8833
This desk covers the treaty only. For UK accounts, investments and pensions, see the United Kingdom country desk.
What we handle for UK residents
The three things that bite US citizens in the United Kingdom.
SIPP & workplace pension
Article 17 (pensions) handles the treaty position; we attach Form 8833 only when you elect a treaty override, otherwise default credit applies.
HMRC tax-year mismatch
We reconcile your April-April SA100 to the IRS calendar year, splitting accrued income on Form 1116 line by line.
Direct answer
Does the US–United Kingdom treaty mean I do not file a US return?
No. Every US income-tax convention carries a saving clause that lets the United States tax its own citizens and green-card holders as if the treaty had not entered into force, with a short list of exceptions. The 2001 convention with United Kingdom decides which country taxes an item first and how double taxation is relieved — usually as a credit on the return you still have to file. Three things it does not do:
It does not remove the filing requirement
The saving clause keeps a US citizen in the United Kingdom inside the US system. Relief for UK tax arrives on Form 1116 (or, for earned income, Form 2555) — on a return, not instead of one.
It does not decide PFIC status
Whether a UK fund or ETF is a passive foreign investment company is a question of US domestic law (IRC §1297), and a treaty does not displace it. A fund inside a local wrapper still reaches Form 8621.
It does not replace the FBAR or Form 8938
The FBAR is a Bank Secrecy Act report to FinCEN and Form 8938 is a return attachment under IRC §6038D; neither is a treaty matter, and the United Kingdom's own foreign-asset filings do not satisfy either.
Filing from the United Kingdom
What the treaty leaves on a return filed from the United Kingdom.
The convention changes how items are taxed; it does not shorten the list of what is reported. A US citizen resident in the United Kingdom typically files:
- Form 1040 on worldwide income, with Schedule B's foreign-account questions answered.
- Form 1116 for the credit on UK income tax — or Form 2555 for earned income, where the exclusion is the better fit.
- The FBAR when non-US accounts together exceeded the threshold at any point in the year, and Form 8938 at its own, higher thresholds.
- Form 8621 for each non-US fund, and Form 8833 only where a treaty position overrides the default.
Missed years change the order: the catch-up route comes first, then the current return.
Other treaty desks
Same workflow, different bilateral convention.
SwitzerlandConvention 1996DenmarkConvention 1999ItalyConvention 1999GermanyConvention 1989FranceConvention 1994CanadaConvention 1980AustraliaConvention 1982
Not sure which desk applies? Every country desk in one place.
United Kingdom treaty · FAQ
What US citizens in the United Kingdom ask us most.
- How is my SIPP or workplace pension treated?#
- Article 17 of the UK-US Convention (2001) governs pensions. We attach Form 8833 only when you elect a treaty override; otherwise the default Foreign Tax Credit on Form 1116 applies. Either way the account is disclosed on Form 8938 / FBAR when thresholds are met.
- How do you handle the UK April-to-April tax year?#
- We reconcile your April-April SA100 to the IRS calendar year, splitting accrued income line by line on Form 1116 so the foreign-tax credit lands in the right US year.
Authorities cited
- US–UK Income Tax Treaty — Convention between the United States and the United Kingdom (signed 2001) and the 2002 Protocol
- U.S.–UK Totalization Agreement — U.S.–United Kingdom Social Security (Totalization) Agreement
- IRS Form 1116 — About Form 1116 — Foreign Tax Credit (Individual, Estate, or Trust)
- IRS Form 8833 — About Form 8833 — Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
United Kingdom guides that go deeper
- FBAR for Americans in the UKHow UK current accounts, ISAs and SIPPs count toward the $10,000 combined-peak FBAR threshold, and how the FBAR differs from Form 8938.Read guide →
- PFICs & Form 8621 for Americans in the UKWhy UK ISAs, investment trusts and OEICs are often PFICs for U.S. persons, and what Form 8621 means for each fund you hold.Read guide →
- The UK ISA and US tax: the exemption stops at the borderAn ISA is the default British way to save and, for a US citizen, one of the least efficient places to hold a fund. The UK exemption is real; it simply has no US counterpart.Read guide →
- The UK SIPP and US tax: a pension, which is not the same as an exemptionUnlike an ISA, a SIPP is a pension — so the US–UK treaty is genuinely in play. That makes the analysis better, and also less certain. This page separates what is settled from what is a position.Read guide →
- U.S. Tax Filing for Americans in LondonFixed-fee support for U.S. citizens and Green Card holders in London — UK salary and PAYE, ISAs and SIPPs, City finance equity, FBAR and FATCA reporting.Read guide →
- Form 1116 for U.S. ExpatsWhat to collect, how income categories and the foreign-tax-credit limitation fit together, and where Atamatax can prepare supported Form 1116 inputs without guessing sourcing questions.Read guide →
Atamatax · run your United Kingdom return
Free on-screen draft. Pay to generate the PDF package.
Scan your brokerage, see your PFIC count, review the forms with the right United Kingdom treaty positions attached. You pay when you generate the draft PDF package. It maps supported figures to IRS forms and identifies items you or your CPA still need to complete.
What you walk out with
- · Form 1040 + schedules B, D, 1, 2, 3
- · One Form 8621 per PFIC (up to 25 per return)
- · Form 8938 (FATCA) when thresholds hit
- · FinCEN 114 (FBAR) threshold check and separate-filing guidance
- · Form 1116 with United Kingdom tax credit allocated
- · Form 8833 when you take a treaty position