US Citizens in the UK - Identifying & Managing Cross-Border Tax Risks

Introduction

Many US citizens living in the UK assume that once they are UK tax compliant, their obligations are fully dealt with. In reality, US citizenship-based taxation means many individuals remain subject to ongoing US reporting and tax liabilities, even after living abroad for decades.

This disconnect can create serious issues in everyday UK financial and estate planning. Routine arrangements, from savings and investments to trusts and pensions, can trigger complex US reporting requirements, punitive anti-avoidance rules, double taxation exposure and significant IRS penalties if not properly addressed.

As a result, UK advisers are increasingly dealing with clients who have US connections, sometimes without either party initially realising it. Failure to identify these issues early can create material risk for both the client and the adviser.

This short webinar will help UK practitioners confidently recognise and manage these cross-border risks. It focuses on the most common estate and tax planning traps affecting US citizens resident in the UK, with clear guidance on how to spot issues, avoid common mistakes and determine when specialist US tax advice is required.

Rather than delving into detailed US technical tax law, the emphasis is on practical risk management, equipping advisers to identify red flags early and protect clients effectively.

What You Will Learn

The webinar will cover the following:

• Why US citizens remain subject to taxation regardless of where they reside
• Identifying ‘hidden’ US connections, including undisclosed citizenship issues
• Risks associated with green card holders and ‘accidental Americans’
• Core differences between UK and US tax systems
• Residence-based versus citizenship-based taxation models
• FATCA reporting obligations and compliance requirements
• FBAR filing requirements and common reporting failures
• US reporting implications of UK bank accounts
• The problematic US tax treatment of ISAs
• PFIC exposure arising from typical UK investment products
• US tax considerations affecting UK pension arrangements
• Tax and reporting issues involving trusts with US persons
• Cross-border implications of gifts to and from US persons
• Interaction between UK inheritance tax and US estate tax regimes
• US tax issues arising from UK property ownership
• Risks associated with joint ownership structures in cross-border cases
• The importance of coordinated UK-US professional advice
• Drafting engagement letters and clearly defining scope of retainer
• Professional negligence risks for UK advisers handling US-connected clients
• Using client questionnaires to identify US connections at onboarding stage
• Key ‘red flag’ indicators requiring immediate specialist US tax referral

This pre-recorded webinar will be available to view from Tuesday 1st December 2026

Alternatively, you can gain access to this webinar and 2,400+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.