Tax and Accounting Advice for
US businesses and individuals

Joined-up tax and advisory support for US and
UK cross-border situations, for businesses and individuals

The US and UK tax systems interact in ways that are often counter-intuitive. Both countries tax their citizens and residents on worldwide income.

The treaty between them helps but does not eliminate the friction – and the gaps between the two systems are where the costliest mistakes tend to occur.

Individuals with US connections and businesses operating in both countries need advisers who genuinely understand how the two regimes fit together and can guide them through the interactions rather than leaving them to reconcile separate opinions from separate advisers.

Our US specialists handles the UK side of cross-border situations and co-ordinates with US tax advisers and CPA firms to deliver a joined-up position.

Related services

How we work on US and UK matters

Each US-UK engagement begins with a clear map of the business or individual’s position. Citizenship and residence status, the entities involved on each side, the income and asset flows and the existing filings in both countries are all set out at the start.

From there, we run the UK work and co-ordinate with the US adviser so the two positions are consistent.

Our services for
US businesses and individuals include

  • UK tax for US citizens and green card holders living in the UK
  • UK tax for UK residents with US source income or assets
  • Treaty analysis and foreign tax credit planning
  • Pre-arrival and pre-departure planning
  • UK set-up for US businesses
  • Transfer pricing between US and UK entities
  • US business owners selling or restructuring UK operations
  • Co-ordination with US CPA firms through PrimeGlobal
  • Cross-border estate and Inheritance Tax planning

Through PrimeGlobal we have direct working relationships with US member firms across the major states.

Where a US filing position needs to be agreed with the UK position, the conversation is between named advisers on each side rather than a referral into the unknown.

What you can expect from our US team

Three principles run through our US and UK work:

A global view

The UK position is given with the US position in view and vice versa. Treaty claims, foreign tax credits and timing differences are planned for, not discovered after the event.

Co-ordinated with a named US adviser

We work directly with a CPA firm on the US side. Where the client does not yet have one, we make a considered introduction through PrimeGlobal to a firm with the relevant specialism.

Practical advice

US-UK personal tax in particular is detail-heavy and full of traps for the unwary. Our advice is given in plain English with the specific implications for the client set out clearly.

Clients with US-UK exposure come to us because they want one trusted UK-side adviser who acts as the guide through the cross-border complexity – co-ordinating with the US side, keeping the two positions consistent and making the detail of a genuinely demanding area manageable.

Here is what our clients have to say… testimonial icon


Why choose Macalvins?

Macalvins is a Top 100 UK accountancy firm and a member of PrimeGlobal, a network of around 300 independent firms across more than 80 countries.

We have considerable experience supporting the needs of US expats and US businesses
operating in the UK.

Speak to our team

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Frequently Asked Questions faq

I am a US citizen who has just moved to the UK. What should I be thinking about?

The first priorities are understanding your UK residence position, working out how the US and UK systems will interact for your income and gains and reviewing any US-based assets and accounts in light of UK reporting requirements. The post-April 2025 changes to the UK rules for new arrivals are particularly relevant. We typically run a structured pre-arrival or first-year review to cover the position systematically.

Does the UK-US tax treaty mean I will not pay tax twice on the same income?

Broadly yes, but the mechanics are more complex than the headline suggests. The treaty allocates taxing rights between the two countries and the foreign tax credit system relieves the resulting double taxation in most cases. The detail of how the credits work, the timing of recognition and the categorisation of different types of income all matter and are where most of the planning sits.

We are a US business setting up in the UK. Can you handle both sides?

We handle the UK side directly and co-ordinate the US side with the client’s existing CPA firm or with a PrimeGlobal member firm where the client does not yet have one. The set-up, the ongoing UK compliance and the transfer pricing between the US and UK entities are all run from our team.

Mr. Jackson
@mrjackson