US expat taxes in the UK — your ISA isn't tax-free to the IRS.
A US citizen living in the UK generally stays inside the US federal filing system on worldwide income. PAYE withholding is usually high enough that the Foreign Tax Credit removes the US tax on salary — so the hard part isn't the tax. It's that HMRC's two flagship tax shelters, the ISA and the SIPP, mean nothing to the IRS, and the funds inside them are commonly PFICs.
A screen from the product type. Whether a specific fund is a PFIC turns on its own annual facts; whether a wrapper is a trust or a pension for US purposes turns on its documents.
What actually applies
The layers a UK return runs through.
Not everyone needs every form. These are the layers that come up most for Americans in the UK, and what makes each one bite here.
US filing layers that commonly apply to a US person living in the UK
PAYE income tax usually exceeds US tax on the same salary. ISA income is UK-tax-free, so there's nothing to credit against whatever US tax applies to it.
The catch-up route for non-willful taxpayers living abroad.
A common path for the long-settled American population across London, Edinburgh and Manchester.
A form listed here does not mean it applies to you. Which of these your return needs depends on your accounts, holdings and income.
Salary and accounts
The easy half of a UK return.
PAYE withholding does most of the work. It is worth knowing which parts are genuinely simple before getting to the parts that are not.
PAYE and the Foreign Tax Credit
Income tax withheld at source under PAYE, plus employee National Insurance, generally exceeds the US tax on the same salary. Form 1116 credits it category by category, and the residual US tax on employment income is commonly zero.
Your P60 and payslips are the cleanest evidence of UK tax actually withheld — exactly what the credit needs, once the April–April period is split to the US calendar year.
A current account, a savings account, an ISA, a Building Society account — each is a non-US financial account. The FBAR adds their peaks together, so accounts that each look modest can cross $10,000 between them.
HMRC treating an ISA as tax-free changes nothing here. The FBAR and Form 8938 layers are independent of UK domestic tax treatment.
It is the standard UK financial advice and, for a US citizen, a standard PFIC problem. Hargreaves Lansdown, AJ Bell, interactive investor and most UK platforms sell Irish- or UK-domiciled OEICs, unit trusts and investment trusts, because there is no US-domicile equivalent on the mainstream UK retail shelf. Generally one Form 8621 per fund per year — inside an ISA or a SIPP just as much as in a general investment account.
Direct shares in Shell, AstraZeneca or Unilever are not PFICs, and neither is a UK gilt held directly.
What HMRC's tax-free wrappers don't change for the IRS.
An ISA and a SIPP are the two products almost every American in the UK ends up holding. Neither reads across to a US return the way you'd expect.
The ISA wrapper carries no US relief
Cash ISA interest is straightforward interest income on a US return. A stocks-and-shares ISA is where it gets harder: the wrapper is invisible to the IRS, and the OEICs or unit trusts typically held inside it are PFICs in their own right.
A SIPP needs classifying before Article 17 applies
Whether a SIPP is treated as a qualifying pension for US purposes, what that means for current-year taxation of growth, and what reporting applies, has to be worked out from the arrangement's own terms — not assumed from the tax-free UK label.
The April–April tax year
HMRC's tax year runs 6 April to 5 April; the US return runs the calendar year. A P60 or SA302 covering the wrong twelve months produces a Foreign Tax Credit claim in the wrong US year unless the periods are reconciled.
Free tool · no account
Check your ISA or SIPP for PFICs.
Pick your platform — Hargreaves Lansdown, AJ Bell, interactive investor, IBKR — and what you hold, or paste the ISINs from your statement.
Result
Tell us what you hold
Pick the closest match on the left, or paste your ISINs below and we'll flag each one.
Educational estimate, not tax advice. Domicile is the fund's legal home, not the broker or exchange you used. Broker and provider policies change — confirm current terms with your provider before acting.
Wise, Revolut, Monzo and the FBAR
Do I report Wise or Revolut on the FBAR from the UK?
Usually yes, with one qualification that decides it: which entity holds the balance. A Wise or Revolut account held by a UK or EU entity is a non-US financial account and its peak counts toward the FBAR aggregate; a balance held by a US-licensed entity is not foreign. The app does not tell you which — the account documents do — and a Revolut ‘Flexible’ fund is a non-US money-market fund on top of that.
Wise (TransferWise)
Which Wise entity holds the account, what a multi-currency balance is worth at the Treasury year-end rate, and what happens when the entity changed mid-year.
Giving up US citizenship from the UK: what Form 8854 asks first.
The second question the UK market types after the app accounts. Renunciation is a consular act; expatriation is a tax event, and Form 8854 certifies five years of compliance before it asks about the net-worth and tax-liability tests.
Form 8854 and the exit tax
What the form certifies, the three covered-expatriate tests, and the mark-to-market deemed sale that follows for a covered expatriate.
The readiness screen returns a five-year timeline — which years need a Streamlined catch-up before Form 8854 can be signed — and opens a secure case for review.
A US citizen or green-card holder living in the United Kingdom who has not filed US returns or FBARs can usually come current through a published IRS route rather than a penalty case. Which route depends on whether returns were filed at all, whether the failure was non-willful, and what UK accounts and investments the open years contain. Nothing is counting down — no IRS-announced end date is currently published.
UK current and savings accounts, cash and stocks-and-shares ISAs, a SIPP and an app account held by a non-US entity all count toward the FBAR aggregate; the funds inside a stocks-and-shares ISA are commonly PFICs, which adds a Form 8621 to every open year.
Accounts readers here usually have to count: Current and savings accounts · Cash and stocks-and-shares ISAs · SIPP · Wise / Revolut / Monzo.
The eligibility check is free and screens the published gates; the case assessment is the paid, per-year review that names the forms and deadlines for your own years.
Behind on filings?
The penalty-free route back, from the UK.
The UK has one of the largest long-settled American populations anywhere outside the US, and a steady stream of people who find out years in. The programme exists for exactly that.
A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs, with the offshore penalty at 0%. Two gates: non-willful conduct, and the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed.
On PAYE salary, the tax across those years is often little or nothing after the credit for UK tax. The volume is in the information returns — a Stocks & Shares ISA held for several years produces one Form 8621 per fund per year across the whole window.
You certify non-willfulness on Form 14653, under penalty of perjury. Atamatax prepares the return side; you write the certification in your own words, assemble the mailing from the package's instructions, and file.
The convention allocates taxing rights and provides relief from double taxation — for a US citizen, almost always as a credit on Form 1116. The saving clause preserves US taxation of citizens subject to the exceptions listed in Article 1.
The UK treaty desk does the article-level work, including how the ISA and SIPP wrappers actually resolve. This page exists for the broader question of what living in the UK does to a US return.
London has its own guide too, for city-level detail on City finance equity compensation and Canary Wharf employers.
The layers a US return runs through don't change by country — what changes is which local accounts, funds and pensions actually trigger them. Here's how United Kingdom compares.
Do Americans living in the UK still have to file US taxes?#
Generally yes. US citizens and green-card holders file a US federal return on worldwide income wherever they live, and UK tax residence does not end that. UK income tax under PAYE is usually high enough that the Foreign Tax Credit on Form 1116 removes most or all of the US tax on salary, but the return and any reporting forms are still required.
No. HMRC's tax-free ISA status is a UK domestic rule with no US counterpart, so income and gains inside an ISA are still reportable on a US return. Cash ISAs are simpler — mainly interest income — but a stocks-and-shares ISA commonly holds non-US pooled funds, which raises the PFIC question independently of the wrapper.
Often, yes. UK platforms typically stock Irish- or UK-domiciled OEICs, unit trusts and investment trusts — non-US pooled vehicles that commonly meet the §1297 income test (75% or more of gross income is passive) or asset test (50% or more of assets produce, or are held to produce, passive income). It is an annual, per-fund test, so each holding should be confirmed rather than assumed. Individual shares in Shell or AstraZeneca are not PFICs.
Do UK bank and building society accounts count for the FBAR?#
Generally yes. A current account, savings account, an ISA and a Building Society account at a UK institution are non-US financial accounts, and the combined peak value across all of them counts toward the $10,000 FinCEN Form 114 threshold — even though HMRC has already taxed or exempted the income. Signature authority over a UK account, even one you don't own, counts too.
Do I need Form 8938 for my UK accounts and investments?#
Possibly, and it is a separate test from the FBAR. For a single filer living abroad Form 8938 starts at $200,000 in specified foreign financial assets at year end or $300,000 at any point; married filing jointly, $400,000 and $600,000. It reaches a broader class of assets than the FBAR — including a SIPP in some cases — so the two thresholds do not move together.
How is my SIPP or workplace pension treated for US tax?#
It depends on the arrangement, and classification comes before any treaty article applies. A SIPP is a defined-contribution personal pension; an employer's auto-enrolment workplace pension is typically occupational. Article 17 of the US–UK treaty addresses pensions, but whether contributions, growth and eventual withdrawals are currently taxable to the US, and what has to be reported, turns on how the specific arrangement is characterised.
Can UK income tax reduce my US tax through the Foreign Tax Credit?#
Generally yes. UK income tax withheld under PAYE on employment income is creditable on Form 1116, computed by income category and limited to the US tax on that category, and it usually exceeds the US tax on the same salary. Dividend and interest income inside an ISA is UK-tax-free, though, which means there is no UK tax to credit — the US liability on that income is not automatically zero just because the wrapper is.
Why does the UK's April-to-April tax year matter for my US return?#
The US return runs on the calendar year; the UK tax year runs 6 April to 5 April. A UK P60 or SA302 does not map onto a US calendar year without splitting the period, which matters for lining up PAYE withholding and any Foreign Tax Credit claim with the correct US tax year.
Can Americans in the UK use Streamlined procedures?#
Living in the UK neither qualifies nor disqualifies you. The Streamlined Foreign Offshore Procedures require non-willful conduct and the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed. A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs with a 0% offshore penalty, certifying non-willfulness on Form 14653.
Does the US–UK totalization agreement affect my National Insurance or Social Security?#
It can. The agreement assigns social-security coverage to one country rather than both, documented by a certificate of coverage, so it governs where contributions are due for a worker moved between the US and UK. It does not by itself change how a pension benefit is taxed once received — that is governed separately by the income tax treaty.
Authorities cited
US–UK Income Tax Treaty — Convention between the United States and the United Kingdom (signed 2001) and the 2002 Protocol
IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (FBAR) — IRM 4.26.16.3.11 Delinquent FBAR Filing Procedures and 4.26.16.5 FBAR Penalties — the examiner standard: no penalty asserted where non-willful, reasonable cause, and the account is properly reported on the late FBAR
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.
Free to start · no card
See what your UK situation actually triggers.
Scan your ISA or SIPP, see your PFIC count, check your FBAR and Form 8938 thresholds, and get the forms your return needs. You pay only to generate the package.