Accountants for US and UK
Americans in Britain file two returns every year, under two tax years, in two currencies. Here is how specialist cross-border accountants prepare and reconcile both, what the work costs in the market, and how to tell a genuine specialist from a generalist.
One household, two tax systems, both returns prepared and reconciled together.
Accountants for US and UK are cross-border specialists who prepare and file both a US federal return and a UK Self Assessment return for the same person, then reconcile the two so that income is taxed once and every foreign tax credit and treaty position is claimed correctly. You need one if you are a US citizen or green card holder living in the UK, a dual national, or anyone with taxable ties to both countries.
That is the short answer. The longer one matters because the two systems were never designed to fit together. The US taxes its citizens wherever they live. The UK taxes whoever is resident here. A London-based American banker therefore sits squarely inside both nets every single year, with two tax years that do not line up, two currencies, two sets of forms and two revenue authorities that share information with each other. Getting one return right is not enough. The two have to agree with each other, or at least disagree for reasons that can be explained line by line.
This page sets out what specialist accountants for US and UK filers actually do, who needs one, how the two returns are reconciled, which forms are involved, what the work costs in the market and how to choose a preparer. It is written by Jungle Tax, a firm that prepares US and UK returns for Americans in Britain, dual nationals, founders, bankers and investors.
- Two returns, every year. US citizens and green card holders in the UK file a US Form 1040 on worldwide income and, if UK resident with taxable income, a UK Self Assessment.
- Double tax is usually avoidable, not automatic. Relief comes through the foreign tax credit, the treaty and careful sequencing, and it only works if both returns are prepared consistently.
- Information reporting carries the sharpest penalties. FBAR, Form 8938 and PFIC reporting apply even when no US tax is due.
- Fees follow complexity. Published fee lists start in the hundreds, but equity compensation, UK funds, property and catch-up years move a household well beyond them.
- Credentials differ by country. An Enrolled Agent or CPA can represent you before the IRS; UK qualifications such as ICAEW, ACCA and CTA speak to the UK side.
What do accountants for US and UK tax actually do?
The job has three parts, and most people only think about the first two. There is the US return, there is the UK return, and there is the reconciliation between them. A firm that treats the third part as an afterthought will often produce two individually defensible returns that, read together, either tax the same income twice or claim relief that the other return does not support.
Preparing your US federal return
For a US person abroad, the core document is Form 1040, reporting worldwide income in US dollars for the calendar year. Around it sit the schedules and forms that make an expat return different from a domestic one: Form 1116 to claim credit for UK tax paid, sometimes Form 2555 for the foreign earned income exclusion, Form 8938 for specified foreign financial assets, Form 8621 for each passive foreign investment company, and Form 5471 where the client controls a non-US company. Separately, and filed with FinCEN rather than the IRS, there is the FBAR (FinCEN Form 114). Where the client still has ties to a US state, a state return may also be required. The IRS sets out the baseline obligations on its page for US citizens and resident aliens abroad, and in Publication 54, the IRS tax guide for citizens living abroad.
Preparing your UK Self Assessment
On the UK side, the return is the SA100 with supplementary pages: SA102 for employment, SA106 for foreign income, SA108 for capital gains, SA105 for UK property and SA109 for residence claims. The UK tax year runs from 6 April to 5 April, figures are in sterling, and HMRC's own Self Assessment guidance explains who must file. Most of our clients file because they have income that PAYE does not fully collect: investment income, gains, bonuses above certain levels, US-source income, or income from their own company. Our dedicated UK tax return service covers the UK side on its own for clients who need only that.
Making the two returns agree
This is where the specialist earns the fee. The UK return is normally prepared first, because UK tax paid is the raw material for the US foreign tax credit. That UK tax then has to be split across two US calendar years, converted to dollars at a defensible rate, allocated to the correct income category and matched against the same income on the US return. A salary, a bonus, a dividend and a gain on a UK fund each travel a different route. Our guide to why the two returns never match explains the underlying reasons in detail; the practical point is that a coherent file explains every difference in writing.
Preparation and compliance, not advisory
We prepare returns, file them, reconcile them and deal with the IRS and HMRC on the positions taken. We do not sell tax schemes or wealth management. That distinction matters to clients who want a firm whose only commercial interest is an accurate, well-documented pair of returns. When a transaction has already happened, such as a share sale, a property disposal or a relocation, our role is to report it correctly on both sides, claim every relief the law already provides, and keep the paper trail that supports those claims.
Who needs a US-UK tax accountant?
Anyone who owes returns in both countries, or who has reporting obligations in one while living in the other. In practice, our clients fall into five groups.
Americans and green card holders living in the UK
The largest group. A US citizen who moves to London for work keeps filing US returns for as long as they hold citizenship, and a green card holder remains a US tax resident until the status is formally ended. If they are UK resident, they also enter the Self Assessment system as soon as they have income that PAYE does not settle. For a first-time filer, our guide for first-time cross-border filers in London walks through the first year.
Dual US-UK nationals
Many dual nationals were born in the US to British parents, left as children and never filed a US return. They are US persons all the same. Some discover this when a UK bank asks them to certify their tax status; others when they try to open an investment account. Their situation is usually a catch-up exercise first and an annual compliance exercise afterwards.
Bankers and executives
Senior employees in financial services carry the richest mix of cross-border issues: bonuses paid in one UK tax year for work in another, deferred awards, restricted stock units that vest over several years and across both countries, and employer tax equalisation arrangements that change who bears the tax. Social security contributions raise a separate question: the US-UK totalization agreement, summarised on the IRS page on international social security totalization agreements, generally stops the same earnings being charged to both systems, and a secondee needs the right certificate of coverage to prove it. We have a separate page for US-UK tax accountants for executives, and another for fund managers with carried interest and co-investment.
Founders and investors
A dual-national founder with a UK company faces US information returns on that company every year and a two-country computation when shares are eventually sold. Investors with UK funds, US brokerage accounts and property in both countries need both returns to treat each asset consistently. Our page for US-UK tax accountants for founders covers the company side.
People moving between the US and the UK this year
The year of a move is the hardest year to file. Residence may be split in the UK, a US state may still claim you, and income earned before and after the move has to be sourced correctly on both returns. A move in September, for instance, puts part of one UK tax year and part of one US calendar year on each side of the Atlantic.
Why do Americans in the UK file two tax returns?
Because the two countries use different tests for who they tax, and a US citizen resident in the UK passes both tests at once.
Citizenship-based taxation
The United States taxes its citizens and green card holders on worldwide income regardless of where they live. Living in London, earning in sterling and paying UK tax does not end the US filing obligation. It changes what is owed, often to nil, but only once the right return has been filed with the right claims. The IRS is explicit that the exclusions and credits which reduce US tax for people abroad are only available if a return is filed.
UK residence and the Statutory Residence Test
The UK taxes by residence, determined under the Statutory Residence Test. HMRC's RDR3 guidance on the Statutory Residence Test sets out automatic overseas tests, automatic UK tests and a sufficient ties test. The broad shape: spend 183 days or more in the UK in a tax year and you are resident; spend very few days here and you are not; in between, your ties to the UK decide. From 6 April 2025 the old remittance basis for non-domiciled individuals was replaced by a four-year foreign income and gains regime, described in HMRC's technical note on the changes to the taxation of non-UK domiciled individuals. More on why that regime can be a poor fit for US citizens below.
The treaty and the saving clause
The US-UK income tax treaty, signed in 2001, allocates taxing rights and provides relief from double taxation. The US text is published by the Treasury as the 2001 US-UK income tax convention, and it takes effect in UK law through the Double Taxation Relief (Taxes on Income) (USA) Order 2002. The catch is the saving clause in Article 1, under which the US reserves the right to tax its own citizens as if the treaty did not exist, subject to listed exceptions. In practice, relief for a US citizen in the UK comes mostly from the foreign tax credit and the treaty's relief-from-double-taxation article rather than from exemptions. The IRS keeps the protocol and technical explanation on its United Kingdom tax treaty documents page. For a deeper treatment of residence, tie-breakers and treaty articles, see our sister pillar on tax specialists for US and UK.
How are the US and UK returns reconciled?
Reconciliation is the flagship skill that separates cross-border accountants for US and UK filers from generalists on either side. Five mechanics drive it.
Two tax years that never line up
The UK tax year runs 6 April to 5 April. The US tax year is the calendar year. Every UK tax year therefore straddles two US years, and UK tax paid has to be apportioned between them before it can be credited. A P60 total is a useful control figure, but it is the wrong input for a US return; payslips and bank credits are what rebuild each calendar year.
| UK tax year | Portion falling in US year one | Portion falling in US year two | What we reconcile |
|---|---|---|---|
| 2025/26 (6 April 2025 to 5 April 2026) | 6 April to 31 December 2025, on the 2025 Form 1040 | 1 January to 5 April 2026, on the 2026 Form 1040 | Monthly salary, bonus dates, dividend dates and UK tax attributable to each slice |
| 2026/27 (6 April 2026 to 5 April 2027) | 6 April to 31 December 2026, on the 2026 Form 1040 | 1 January to 5 April 2027, on the 2027 Form 1040 | The same, plus any payments on account that relate to the year |
The consequence is that the US return for 2026 cannot be finished accurately until the UK position for part of 2026/27 is known. Good preparers build that timing into the engagement rather than filing a US return on estimates and amending it later.
Foreign tax credit or foreign earned income exclusion?
US persons abroad have two main tools. The foreign earned income exclusion on Form 2555 removes a capped amount of foreign earnings from US tax. The foreign tax credit on Form 1116 credits UK tax paid against US tax on the same income. You cannot claim a credit for tax on income you have excluded.
For most high earners in the UK, the credit is the stronger choice. UK tax on employment income at higher and additional rate levels is often greater than the US federal tax on the same income, so the credit frequently wipes out US tax on earnings and leaves unused credit that can be carried to other years. The exclusion, by contrast, is capped, does not cover investment income, and once revoked cannot simply be re-elected at will. Our FEIE vs FTC calculator shows the comparison for your own figures, and the choice is always confirmed against both returns before we file.
Credit categories, carryovers and the NIIT problem
The foreign tax credit is computed separately for different categories of income, broadly general income such as salary and passive income such as dividends and interest. Excess UK tax on salary cannot shelter US tax on passive income. Unused credit can be carried to other years within statutory limits, so a well-kept carryover schedule is an asset that grows in value over time. Lose track of it, which happens when a client changes firms without a proper handover, and the relief is effectively forfeited. Our guide on changing firms mid-catch-up covers what a clean handover file should contain.
Then there is the net investment income tax. The IRS applies a 3.8 percent net investment income tax once modified adjusted gross income exceeds $200,000 for a single filer or $250,000 for a married couple filing jointly. The IRS position is that the Form 1116 credit does not reduce it, so a UK resident with significant dividends or gains can owe US tax even though their UK tax bill is larger. It is one of the first things we check on a high-income file.
Currency conversion
Every sterling figure has to become a dollar figure. Income is generally converted at the rate on the date received or at a yearly average rate, used consistently. Capital gains need the dollar cost at acquisition and the dollar proceeds at sale, which means a UK property or share can show a larger or smaller gain in dollars than in pounds, and sometimes a gain in one currency and a loss in the other. FBAR balances use the Treasury's year-end rate. Mixing these methods is one of the commonest defects we find on returns prepared elsewhere.
A worked scenario
Consider a London-based American banker, UK resident for several years, paid a salary monthly and a bonus each March, with a UK brokerage account and a small US account left behind. The UK return for 2025/26 is prepared first: employment income on SA102, UK dividends and interest on the main return, US dividends on SA106 with credit for any US tax withheld, gains on SA108. We then split the UK tax on the salary by month and the tax on the bonus to the calendar year in which it was paid. On the 2025 US return, the salary and bonus go in the general category, UK tax attributable to them is converted and credited, and the excess credit is carried forward. The dividends go in the passive category with their own credit. Finally, NIIT is computed on the investment income and not offset by the credit. Two returns, one coherent story, each figure traceable.
Which forms does a US-UK accountant file for you?
The form list is where competitors often stop. The useful question is which form a given part of your life triggers, on each side.
| Your situation | US forms | UK forms |
|---|---|---|
| UK salary, bonus or directorship | Form 1040, Form 1116 (or Form 2555) | SA100, SA102 |
| UK and US bank or brokerage accounts | FinCEN Form 114 (FBAR), Form 8938, Schedule B | SA100 for UK interest and dividends; SA106 for foreign income |
| UK funds, including those held in an ISA | Form 8621 for each PFIC | Usually nothing inside an ISA; SA100 or SA108 outside it |
| A UK company you control | Form 5471, with its own schedules | SA102 for salary; SA100 for dividends |
| Rental property in either country | Schedule E | SA105 for UK property; SA106 for overseas property |
| Sale of shares, funds or property | Form 8949 and Schedule D | SA108 |
| Residence, split year or FIG claims | Form 8833 where a treaty position must be disclosed | SA109 |
| Years not filed | Prior-year returns, Form 1040-X, Form 14653 under Streamlined | Late returns for each missing year |
| Authority to act for you | Form 8821 or Form 2848 | HMRC agent authorisation |
That final row is often overlooked. Before we can speak to either revenue authority on your behalf, you have to authorise us. Our guide to agent authority on IRS Form 2848 and HMRC form 64-8 explains what each authorisation permits.
FBAR and FATCA: the reporting with the sharpest penalties
Income tax errors are usually corrected with tax and interest. Information reporting errors can attract penalties even when no tax at all is due, which is why they deserve their own section.
FBAR thresholds and deadlines
A US person must file an FBAR if the aggregate value of their foreign financial accounts exceeds $10,000 at any time during the calendar year, according to FinCEN's guidance on how to report foreign bank and financial accounts. The test is aggregate, so three UK accounts holding $4,000 each trigger it. The FBAR is due by 15 April with an automatic extension to 15 October, and it is filed electronically with FinCEN, not with the tax return. Signature authority counts too: a finance director who can sign on a UK company account may have to report it. You can estimate your exposure on our FBAR penalty calculator.
Form 8938 for filers living abroad
Form 8938 overlaps with the FBAR but is a separate filing, attached to the return, with higher thresholds for people living outside the US. Per the IRS comparison of Form 8938 and FBAR requirements, an unmarried filer abroad reports if specified foreign assets exceed $200,000 on the last day of the year or $300,000 at any time; for a married couple filing jointly the figures are $400,000 and $600,000. Many of our clients file both forms, reporting the same accounts twice in slightly different ways.
How UK banks report you
UK financial institutions identify US persons among their customers and report their accounts to HMRC, which passes the information to the IRS under the intergovernmental FATCA arrangements. This is why UK banks ask about US citizenship and place of birth. The practical consequence is simple: the IRS may already know about accounts that have never appeared on an FBAR. Reconciling what we file against what the banks are likely to have reported is part of every onboarding.
What complications separate a specialist from a generalist?
Straightforward returns are within reach of any competent preparer. Wealthy cross-border households are not straightforward, and the following issues are where errors cost the most. Our high-net-worth US-UK service is built around them, as is our private client tax return service.
RSUs, options and bonuses spanning two years
Equity awards typically vest over several years. If you worked in New York when an award was granted and in London when it vested, both countries may claim a share of the same income, apportioned by workdays in each location. The UK taxes the award through payroll at vest; the US taxes it on the calendar-year return; each allocates foreign-source and domestic-source portions differently. Bonuses paid in March for work in the preceding calendar year raise the same sourcing and timing questions. The files that go wrong are almost always the ones where nobody built a workday schedule.
UK funds and ISAs
An Individual Savings Account is tax-free in the UK and ordinary in the US. The wrapper means nothing to the IRS, so income and gains inside an ISA are reportable on the US return. Worse, most UK-domiciled collective funds, including OEICs and exchange-traded funds held in an ISA or a general account, are passive foreign investment companies for US purposes. Each one may need its own Form 8621, and the default PFIC tax regime is punitive unless an election is made and maintained. We see more US exposure from well-meant UK savings than from almost anything else.
Selling a UK home or investment property
A UK main residence sale may be free of UK capital gains tax and still produce a US gain, because the US computes the gain in dollars and applies its own exclusion for a main home, with its own conditions and a dollar ceiling. Paying off a sterling mortgage can also create a currency gain for US purposes. Investment property adds depreciation on the US side, which the UK does not recognise in the same way. Both returns report the same sale; neither computes it like the other.
Founder share sales
When a dual-national founder sells shares in a UK company, the UK computation may include reliefs such as Business Asset Disposal Relief, which the US return does not recognise. The US side has its own rules, and if the company was a controlled foreign corporation, earlier Form 5471 filings affect the result. The sale also generates UK capital gains tax that has to be credited, where possible, against US tax in the right category and year.
The FIG regime and why it can backfire for US citizens
Since 6 April 2025, new UK residents who have been non-resident for the previous ten tax years can claim the four-year foreign income and gains regime, set out in the Finance Act 2025. Qualifying foreign income and gains are then not taxed in the UK. For most people that is simply good news. For a US citizen it can be neutral or harmful: US tax on that income remains, there is no UK tax to credit against it, and HMRC's technical note confirms that anyone who claims the regime loses the personal allowance and the capital gains annual exempt amount for that year. Claims are made year by year on SA109, so the right answer can differ from one year to the next. We model both versions of the return before deciding which to file.
State tax ties that follow you abroad
Some US states are reluctant to let former residents go. Keeping a house, a driving licence, a voter registration or a family base in certain states can leave you filing a state return years after moving to London, and states do not generally give credit for UK tax the way the federal return does. Establishing the state position in the year of the move is far easier than arguing it later.
Behind on US filings? How catch-up works
Many Americans in the UK, and most accidental Americans, arrive at a specialist with years of unfiled US returns. The good news is that the IRS provides a formal route back for people whose failure was not wilful. Our guide to missed US tax returns for Americans in the UK covers the first steps.
The Streamlined Foreign Offshore Procedures
Under the Streamlined Filing Compliance Procedures, a US citizen or green card holder living abroad can file the most recent three years of delinquent or amended returns and the most recent six years of FBARs, pay any tax and interest due, and certify on Form 14653 that the failure was non-wilful. The IRS page on the Streamlined Foreign Offshore Procedures sets the non-residency test: in at least one of the three most recent years, no US abode and at least 330 full days outside the United States. A taxpayer who qualifies and follows the instructions is not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. The certification narrative is the heart of the submission and must be accurate; it is not a formality. Our IRS Streamlined filing service handles the full package, and our guide to Streamlined filing for high-net-worth households covers the harder cases. For an early sense of the liability, try the US back tax calculator for expats.
Late UK Self Assessment returns
HMRC's penalties for late returns are mechanical. According to GOV.UK, an initial £100 penalty applies once the return is late, daily penalties of £10 can follow after three months up to a maximum of £900, and further penalties of 5 percent of the tax due or £300, whichever is greater, arise at six and twelve months. Interest and late-payment penalties run separately. Our UK late filing penalty calculator gives an estimate for each missing year.
US and UK tax deadlines in one calendar
Two authorities, two years and one household. This is the calendar we work to, drawn from the IRS, FinCEN and HMRC's Self Assessment deadlines page.
| Date | Authority | What falls due |
|---|---|---|
| 31 January | HMRC | Online Self Assessment return for the tax year ended the previous 5 April; balancing payment and first payment on account |
| 15 April | IRS and FinCEN | Regular due date for Form 1040 and for US tax payment; FBAR due date |
| 15 June | IRS | Automatic two-month extension to file for US citizens and residents living abroad; interest still runs from 15 April |
| 31 July | HMRC | Second payment on account |
| 5 October | HMRC | Deadline to register for Self Assessment if you need to file for the first time for the previous tax year |
| 15 October | IRS and FinCEN | Extended due date for Form 1040 if Form 4868 was filed before 15 June; automatic FBAR extended date |
| 31 October | HMRC | Paper Self Assessment return deadline |
Two details catch people out. First, the US automatic extension for people abroad extends the time to file, not the time to pay, so interest accrues on unpaid US tax from 15 April. Second, the UK payment on account system means a first-year filer can face a January bill covering both the previous year and half of the current one. Our year-end checklist for Americans in London is built around these dates.
How much do accountants for US and UK charge?
There is no standard price, and the firms that publish fees tend to publish their floor rather than a typical HNW engagement. Here is what the market shows publicly, without naming firms, and what drives the number up.
Published fee ranges in the market
Published fee lists from US-UK firms start from around USD 565 for an annual US return, with some London firms quoting a minimum of around £900 plus VAT for Form 1040. For a couple with investments and a rental property, published figures for the US return alone run to around £1,300 to £1,550 plus VAT, and a mid-year move between the two countries including a part-year state return is quoted at around £1,350 to £1,650 plus VAT. UK Self Assessment fees published by US-UK specialists range from about £299 plus VAT to around USD 910. A Streamlined catch-up package of three returns and six FBARs is listed from around USD 1,750, and one-off consultations are priced from roughly USD 190 by email to £550 for a thirty-minute call. The guide to fees and timelines for multi-year catch-up puts these in context.
What drives the fee
| Fee driver | Why it adds work |
|---|---|
| Number of accounts and institutions | Each account must be valued in dollars for FBAR and Form 8938 and reconciled to income reported |
| UK funds and ISAs holding funds | Each PFIC can need its own Form 8621 and annual computations |
| Equity compensation | Workday sourcing across years and countries, and matching payroll figures to vesting records |
| Property in either country | Rental schedules on both returns, depreciation on the US side, currency gains on sale and mortgage repayment |
| A company you control | Form 5471 or similar information returns, with their own penalty regime |
| A move during the year | Split-year treatment in the UK, part-year state returns and dual sourcing |
| Catch-up years | Each year is a full return pair, plus FBARs and the Streamlined certification |
| Quality of records | Missing broker statements or cost basis mean reconstruction before preparation can start |
Fixed fees and engagement letters
A good engagement letter states which returns and forms are included, how many accounts and funds the fee assumes, whether state returns are in scope, how queries during the year are handled, and what happens if the facts turn out to be more complex than described. At Jungle Tax we quote fixed fees after scoping and put them in writing before work starts. The worst cross-border fee is a low headline number that excludes the FBAR, the Form 8621s and the state return, and only discloses this when the invoice arrives.
What qualifications should a US-UK tax accountant have?
Competitors assert credentials without explaining them. The table below sets out what each one actually means. The IRS explains US credentials on its page on understanding tax return preparer credentials and qualifications.
| Designation | Awarded or licensed by | What it shows | Standing before the IRS | Standing before HMRC |
|---|---|---|---|---|
| CPA | US state boards of accountancy | Broad US accounting and audit qualification; tax depth varies by individual | Unlimited representation rights | Can act as agent if authorised by the client |
| Enrolled Agent (EA) | The IRS, after a three-part Special Enrollment Examination | Specialist US tax credential with continuing education requirements | Unlimited representation rights | Can act as agent if authorised by the client |
| ICAEW Chartered Accountant (ACA) | UK chartered accountancy body | Broad UK accounting qualification with professional regulation | No representation rights from this alone | Can act as agent if authorised by the client |
| ACCA | UK-based chartered certified accountancy body | Broad accounting qualification, widely held in practice | No representation rights from this alone | Can act as agent if authorised by the client |
| CTA | UK chartered tax adviser body | Advanced UK tax specialist qualification | No representation rights from this alone | Can act as agent if authorised by the client |
| ATT | UK tax technician body | Practical UK tax compliance qualification | No representation rights from this alone | Can act as agent if authorised by the client |
What "dual-qualified" should mean
It should mean that the team preparing your returns includes someone holding a recognised US credential and someone holding a recognised UK credential, and that both actually work on your file. It should not mean a UK firm with a referral arrangement to a US preparer who never sees the UK return, or the reverse. Any paid US preparer needs a preparer tax identification number; representation in an IRS examination needs an EA, CPA or attorney.
Is tax work regulated in the UK?
Less than most clients assume. In general, anyone can describe themselves as an accountant or tax adviser in the UK; the protection comes from membership of a professional body, which imposes its own standards, insurance and discipline. HMRC's own requirements for advisers who interact with it on clients' behalf have been tightening, and any firm you engage should be able to tell you how it meets them. Ask any prospective firm which body regulates it and whether it holds professional indemnity insurance.
Which type of US-UK accountant suits your situation?
There are four broad models in the market. Each has a place; the question is fit.
| Model | Prepares both returns? | Handles HNW complexity? | Reconciles the two returns? | Access to your preparer |
|---|---|---|---|---|
| Specialist US-UK preparation firm | Yes, usually in-house | Yes: PFICs, equity, property, entities | Yes, as a core process | Direct, with a named preparer |
| Online US expat platform | US side; UK often separate or limited | Varies; complex files may cost extra or be declined | Limited unless both returns are in scope | Usually through a portal |
| UK high-street accountant | UK side only in most cases | UK side yes; US side no | No, unless paired with a US preparer | Direct |
| Large multinational accountancy firm | Yes, often across separate teams | Yes | Yes, often within wider service lines | Varies with seniority and fee level |
If your US and UK returns are both material, a firm that prepares both is almost always the better answer, because reconciliation is where the value lies. If you are unsure whether you need a specialist at all, our decision guide on when a specialist is required sets out the tipping points.
How does working with Jungle Tax work?
Every engagement follows the same sequence, whether it is a single year or a multi-year catch-up.
- Introductory call. We establish citizenship, residence history, income sources, accounts and any unfiled years. You can start through our contact page.
- Scoping and fixed fee. We confirm which returns and forms are in scope and set a fixed fee in an engagement letter.
- Authorisations. You authorise us with HMRC and, where needed, with the IRS through Form 8821 or Form 2848.
- Document collection. P60, P11D, payslips, bonus and vesting statements, UK and US broker statements, 1099s, property records and prior returns, uploaded securely.
- UK return first. We prepare the Self Assessment, because UK tax paid feeds the US credit.
- US return reconciled. We apportion UK tax across calendar years, convert currency consistently, compute credits by category and prepare FBAR, Form 8938 and any Form 8621s.
- Review. We walk you through both returns together, including a written reconciliation of any differences.
- Filing and follow-up. We file both returns electronically where possible, keep the carryover schedules, and deal with correspondence from either authority.
For a full list of what to ask on that first call, see our guide on questions to ask before you engage a preparer in London. Our US tax return service also sets out the US-only scope for clients whose UK affairs are already handled.
What should you ask before you hire a US-UK accountant?
A short checklist that separates specialists from generalists:
- Will the same firm prepare both my US and UK returns, and who reviews them?
- Who on the team holds a US credential with IRS representation rights, and who holds a UK qualification?
- How do you apportion UK tax across US calendar years, and which exchange rates do you use?
- How do you handle UK funds and ISAs under the PFIC rules?
- Do you keep my foreign tax credit carryover schedule and pass it on if I leave?
- Exactly which forms, accounts and states does your fee cover?
- How will you handle IRS or HMRC correspondence after filing?
Speak to accountants who prepare both returns
The right accountant for a US-UK household is one who prepares both returns, reconciles them in writing, and files the information reports that carry the real penalty risk. That is the whole of what we do. To discuss your returns with our US-UK tax accountants, get in touch with Jungle Tax and we will confirm scope and a fixed fee before any work begins.
