I moved back to UK and my UK accountant says HMRC is saying that I should pay UK tax first and claim back from USA . Last year I paid tax in USA and then it was credited to UK . Anyone know anything about this ? How about you Durham Lad?

You only get a credit for tax’s paid if they are owed, you can’t choose where… what is the source of the income ? Is it US W2/1099 or UK PAYE or other?

If you are working PAYE in the UK it would be owed there and if you are a USC you then file your US return and claim the credit…

It could get complicated if it’s a US sources income for work perform in the UK.

It's going to depend very much on sources of income, residency, nationality / green card status - basically, your unique personal situation. Have you asked your accountant to provide more details on what has changed from year to year? That might help folks give you more detailed feedback or chime in based on their own experience.

I lived in USA for 40 years and my pension is USA . All my income is from USA .

+1, you need to provide a lot more detail.

In my case I have US and UK private pensions as income and I pay US taxes and HMRC taxes on it all, claiming foreign tax credits against my US taxes for taxes paid to HMRC. When I start receiving US SS next year it will only be taxed by HMRC.

Thx for all responses. I am a dual citizen, married an American who passed away and I moved back home . I basically have USA Cal state pensions and some funds . I just sold my home in Cal this year so have cut ties with the USA except for my income and tax obligation. I'm really not sure how well my UK tax accountant understands the USA/ UK tax situation. I found it hard to find an accountant here in north of England who gives me confidence ce

Thx DL . I have no income from UK . I have Cal State pension and part of my husbands USA government pension , no social security pension. I have an HSBC account for USA and UK . I hvae in past paid USA tax in Jan for USA year and then claimed credit for that from UK when I filed in April

If you're not confident that your UK accoutant is comfortable with the US/UK tax treaty then try to find another. Doesn't have to be local, most firms are used to dealing with remote clients these days. If you look back through threads here you might find some names, though probably mainly in London. You may also need to consult a US-focused firm to help you with your IRS and State filings there, at least for a transitional period until you figure out the pattern. In the meantime, get a copy of the UK/US Double Taxation Agreements and go through it yourself, pay particular attention to the sections that cover your income sources (Pensions, dividends, interest.) Also, you mention funds - not sure if you mean mutual funds or generic 'fund of money'. There are different UK tax treatments for offshore funds depending on what type of fund it is and whether it has registered with HMRC as a Reporting Fund. I'm still trying to wade through this quagmire myself but essentially the type of offshore fund impacts whether gains are treated as capital gains (currently lower tax rates) or income.
None of this will necessarily help you understand why things changed year over year - but again, your accountant should be able to explain that to you and if they cannot then I'd take that as another sign to replace them.

Thanks for your response. I have mutual funds with Schwab in USA .. I'm. trying to find out as much as I can. I just had never heard of anyone paying the UK tax first and then claiming back from USA .. On the posts I've read in the past on this site, it seemed that when people move back to UK , they had paid USA tax first and used the credit on UK tax obligations .. Thanks for everyone's input

HMRC is usually the primary taxing authority but that depends on the type of income, and who taxes what is explained in the US-UK tax treaty. Below is a link to the treaty plus I have added a list of tax accountants you may wish to contact.

https://www.irs.gov/businesses/inter...eaty-documents


Some of the below have been recommended by posters on this site. Some are inexpensive (less than $400), some are expensive ($1,000+).


https://www.greenbacktaxservices.com/

https://britishamericantax.com/

Expatriate Tax Services | US & US Expat Tax Returns | Ingelton Partners

https://www.hrblock.com/expat-tax-pr...caAtw7EALw_wcB

https://www.taxesforexpats.com/

https://www.usglobaltax.co.uk/

https://www.americanuktaxsolutions.com/about-us.html

http://www.americantaxreturns.co.uk/

https://www.frankhirth.com/

Unless they are registered with HMRC as Reporting Funds, gains would likely be taxed by HMRC as offshore income rather than capital gains. HMRC maintains a list of registered reporting funds here: https://www.gov.uk/government/public...eporting-funds
I found out several of my US holdings were not registered so am currently working with my US advisor to sell and reinvest in ones that are on the list. I only learned about the whole reporting/non reporting thing recently from an old post on a different forum, so do spend some time searching on keywords and look at posts for the last couple of years on various forums for some good info.

Remember your FBAR for your non US-based bank account(s.)

I'm sure everything feels overwhelming but hopefully you'll be able to connect with an accountant with more experience helping expats who can help you prioritize.

Thank you DL ..