60 days
UK CGT Reporting
Property is where US and UK tax rules diverge most visibly. The US requires depreciation on a rental that the UK ignores. The UK restricts mortgage interest relief that the US allows in full. A sale can produce a currency gain in one country that does not exist in the other. Owning property across the Atlantic means running two calculations that rarely agree, and filing both correctly.
We act for US persons letting or selling UK property and for UK residents buying or selling in the US. The work spans annual rental reporting, disposal planning, withholding relief under FIRPTA and the non-resident landlord scheme, and the tight deadlines, like the UK's 60-day capital gains reporting window, that catch owners by surprise.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Property & Financing Review
We map each property, its ownership structure, and its mortgage, since foreign-currency debt creates its own US tax consequences.
Rental Reconciliation
We compute the US and UK rental results side by side, applying required US depreciation and the UK's restricted interest relief.
Withholding Management
We handle the non-resident landlord scheme for UK rentals and FIRPTA withholding relief for US sales, so gross cash flow is not needlessly trapped.
Disposal Planning
Before a sale, we model the gain in both countries, including exclusions, currency effects, and the rate each jurisdiction will apply.
Deadline Calendar
We track the deadlines that bite: the UK 60-day CGT return, US estimated payments, and withholding certificate lead times.
Annual Filing
We prepare the returns on both sides, from Schedule E and Form 1040-NR to UK property pages, with the two kept consistent.
UK Rental Reporting
One rental, two profit calculations.
A US person letting a UK flat files rental accounts in both countries, and the numbers will not match. The US requires depreciation on the building whether you claim it or not, and the IRS treats it as taken when you sell. The UK, meanwhile, restricts mortgage interest relief for individual landlords under Section 24 to a basic-rate credit, while the US still allows the interest in full. The result is two genuinely different taxable profits from the same tenancy.
Foreign-currency mortgages add a quieter trap. When you pay off or refinance a sterling mortgage, US rules can treat the currency movement on the debt as a taxable exchange gain, income with no cash behind it. We calculate this exposure before a remortgage or sale, not after, because timing is the only real lever.
Rental focus: required US depreciation, the Section 24 interest mismatch, Schedule E reporting, and Section 988 exchange gains on mortgage redemption.
Tailored for every client profile.
Disposal Planning
The gain HMRC sees is not the gain the IRS sees.
Selling your UK main home may be free of UK tax under private residence relief, but the US exclusion under Section 121 is capped, currently $250,000 per person or $500,000 for a qualifying couple, and only applies if ownership and use tests are met. Gains above the cap are taxable in the US even when the UK charges nothing, and depreciation claimed during any rental period is recaptured on top.
Currency does the rest. The US measures your gain in dollars, using the exchange rate on the day you bought and the day you sold. A decade of sterling movement can manufacture a large dollar gain from a modest sterling one. UK residents selling UK residential property must also report and pay any UK CGT within 60 days of completion, a deadline that arrives long before the annual return.
Disposal focus: Section 121 exclusion limits, depreciation recapture, dollar-measured currency gains, and the UK 60-day CGT return.
US Investment Property
Getting your money out from under FIRPTA.
When a foreign owner sells US real estate, FIRPTA generally requires the buyer to withhold 15% of the gross sales price, not the gain. On a property sold at a small profit, that withholding can dwarf the actual tax. Filing Form 8288-B before closing can reduce or eliminate the withholding, and a Form 1040-NR after year end reports the true gain and recovers any excess. The sequencing matters, because a late application means waiting on a refund instead of keeping your cash at closing.
Ownership itself needs thought before purchase. Stamp duty and transfer costs apply on the way in, both countries can tax the rental income, and US estate tax reaches US property held by a non-resident with an exemption of only $60,000. How the property is held, personally or through a structure, should be decided before contracts are exchanged, not discovered at probate.
Inbound focus: FIRPTA 15% withholding, Form 8288-B relief, Form 1040-NR reporting, and estate exposure on both sides of the Atlantic.
Buying, letting, or selling across the Atlantic?
The costly property mistakes are made before completion, not after. Get the two-country numbers run while there is still time to act on them.
Specific deliverables, precisely documented.
“Two countries will each measure your property their own way. Our job is to make sure you pay tax on the real economics, once, and on time in both.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
Yes. US law treats depreciation as 'allowed or allowable', which means the IRS assumes you took it whether you did or not, and recaptures it when you sell. Skipping depreciation does not avoid the recapture; it just costs you the deductions along the way.
Mostly interest and depreciation. The UK's Section 24 rules restrict an individual landlord's mortgage interest relief to a basic-rate credit, while the US deducts the interest in full but requires depreciation the UK does not recognize. Two rulebooks, two profits, and credits have to reconcile the tax on each.
FIRPTA requires the buyer of US real estate from a foreign seller to withhold, generally 15% of the gross price. Because it is charged on price rather than gain, it usually overshoots the real tax. A Form 8288-B application filed before closing can reduce the withholding to the actual liability, and a 1040-NR recovers any remainder.
Disposals of UK residential property must be reported to HMRC on a standalone return, with any capital gains tax paid, within 60 days of completion. Non-resident sellers must file even when no tax is due. It runs completely separately from the annual Self Assessment deadline, and penalties accrue quickly.
Related services.
Two Tax Systems, One Team
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