US-UK Tax Accountants for Fund Managers
Carry, K-1s, co-invest and deferred comp each land in two tax systems on different timelines. We prepare your US and UK returns together so every stream is reported once, correctly, on both sides.
Fund economics are complex enough in one country. Across two, the reporting is where value quietly leaks
GPs and fund principals who are US persons in the UK — or dual nationals — sit at the intersection of the two most demanding tax systems in the world. Carried interest, management fee, co-investment and deferred compensation are each characterised and timed differently by the IRS and HMRC, and each flows through several vehicles and K-1s.
Get the coordination wrong and the same carry can be taxed twice, a PFIC holding can trigger punitive US treatment, and a deferred-comp mismatch can surface a liability years after the award. Generalist advisers rarely see the whole board.
We prepare both returns as a single engagement — reconciling every K-1, applying the treaty and foreign tax credit, and reporting each income stream once in each jurisdiction. Accurate, defensible filings across your entire structure.
What we prepare for fund professionals
Carried interest, both sides
US and UK reporting of carry under each system’s rules, with treaty relief applied so the same award is not taxed twice.
US K-1 reconciliation
We take your management, carry and co-invest K-1s and carry the right figures onto your UK Self Assessment with correct timing and FX.
PFIC reporting (Form 8621)
Identification of passive foreign investment company exposure across your holdings, with the required reporting and elections prepared.
Deferred & non-qualified comp
Cross-border deferred compensation reported consistently across both timelines so a US–UK move does not create double taxation.
Foreign accounts (FBAR & FATCA)
Complete FBAR and Form 8938 reporting across personal and vehicle accounts, however many jurisdictions they span.
Catch-up for unfiled years
IRS Streamlined Filing, where you qualify, to bring back years and FBARs current with no penalty — handled discreetly.
One team for both tax systems
Whole-structure view
Every K-1, vehicle and income stream reconciled across both tax systems, not in isolation.
Carry & PFIC fluency
The founder- and fund-specific filings that catch principals out are core work here.
Preparation & compliance
Accurate, defensible returns grounded in your actual economics — not investment advice.
Discretion by default
Senior, confidential handling for high-value, sensitive cross-border positions.
Questions & Answers
Carried interest sits in two tax systems at once, and the US and UK characterise and time it differently. As a US person you report your share to the IRS on your worldwide income, while the UK applies its own carried interest rules to the same award. We prepare both returns together, apply the treaty and foreign tax credit correctly, and make sure the same carry is not taxed twice or reported inconsistently across the two sides.
Yes. We take your US Schedule K-1s, prepare the US reporting, and translate the relevant income and gains onto your UK Self Assessment return with the right timing and exchange rates. Fund principals often hold several K-1s across management, carry and co-invest vehicles, and the reconciliation across both jurisdictions is exactly what we do.
They can. Many pooled and offshore fund holdings are passive foreign investment companies for a US person, which triggers Form 8621 and some of the least forgiving rules in the US code. We identify PFIC exposure across your holdings, prepare the required reporting, and handle any available elections as a preparation matter — not as investment advice.
We map each income stream — management fee, co-investment return, carried interest — to how it is taxed in both the US and UK, prepare the returns so each is reported once in each system, and apply treaty relief and foreign tax credits so you are not double taxed. The aim is accurate, defensible filings across every vehicle you hold.
Cross-border deferred compensation and Section 457A / non-qualified arrangements are taxed on different timelines in the two countries, which can create mismatches and unexpected double taxation if handled in isolation. We prepare both returns with the deferral treated consistently and the treaty applied, so the timing works across your move rather than against it.
Yes, and discreetly. Where you qualify as non-wilful, the IRS Streamlined Filing Compliance Procedures allow a set number of back years and FBARs to be brought current with no penalty. We assess eligibility, prepare the package including any K-1, PFIC and foreign-account reporting, and sequence it against any UK disclosure.
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Ready to discuss your US-UK tax situation? Contact Jungle Tax today to explore how we can help with your cross-border tax compliance and planning needs.