Cross-Border Investors
PFIC analysis, withholding and treaty rates, reporting fund status, crypto, and gains timing: investment tax handled coherently across the US and UK by one team.
Two returns, one plan.
An investment that is perfectly sensible in one country can be a tax accident in the other: a UK tracker fund becomes a PFIC to the IRS, a US ETF without reporting status turns UK capital gains into income. We analyze the portfolio under both systems and rebuild it so every holding works on both sides.
From account setup and withholding certificates to disposals, crypto, and estate exposure, we handle the reporting and the structural decisions together.
How we help cross-border investors
Portfolio analysis, reporting, and planning for assets held across the US and UK.
PFIC Analysis & QEF Elections
Most UK and EU funds are PFICs to a US investor, with punitive default treatment. We identify every PFIC in the portfolio, prepare Form 8621, and make QEF or mark-to-market elections where they genuinely help.
UK Investors in US Markets
W-8BEN certification, treaty withholding rates on dividends, and the US estate tax exposure that starts above $60,000 of US-situs assets for non-domiciliaries. We manage the paperwork and the exposure together.
Reporting Fund Review
For UK taxpayers, offshore funds without UK reporting fund status turn gains into income taxed at higher rates. We screen holdings for reporting status and restructure toward funds both systems treat as capital.
Sourcing & Treaty Rate Positions
Where a dividend or interest payment is sourced decides who taxes it first and what credit the other country must give. We apply the treaty's sourcing and rate rules so nothing is taxed twice at full rates.
Crypto Across Borders
The US and UK both tax crypto disposals, but with different pooling rules, different rates, and different reporting. We reconcile your transaction history once and report it correctly in both systems.
Gains Timing & Wrapper Strategy
Misaligned tax years and different exemptions mean the timing of a disposal can change the total bill materially. We plan sales across both calendars and build portfolios in wrappers that work on both sides.
Get your portfolio reviewed under both systems before the next trade.
Get StartedExplore our tax services
Built for portfolios that cross the Atlantic.
Cross-border investment tax is won or lost at purchase: the wrapper you choose, the fund's domicile, the withholding certificate on file. We put the analysis in front of the trade, and clean up efficiently when the trade came first.
The wrapper matters as much as the investment.
ISAs the US ignores, 401(k)s the UK respects, funds one system taxes as income and the other as gains: the same asset can produce wildly different outcomes depending on how and where it's held. We map which wrappers genuinely work in both systems and move you out of the ones that don't.
Fund-by-Fund PFIC Screening
Every pooled investment in the portfolio is classified under US rules before it causes damage, and Form 8621 positions are chosen deliberately rather than by default.
Reporting Fund Verification
We check offshore holdings against HMRC's reporting fund list so gains stay capital gains, and swap out funds that would be taxed as income.
Estate Exposure for Non-Domiciliaries
US-situs holdings above $60,000 carry US estate tax risk for non-US investors. We quantify it and restructure through treaty-aware alternatives where warranted.
Dual-Calendar Disposal Planning
April 5 and December 31 create a permanent misalignment. We schedule significant sales so gains, losses, and credits land in the right year in both systems.
Why cross-border investors choose US/UK Cross Border Tax
Portfolio-Level Analysis
We review holdings line by line, fund by fund and wrapper by wrapper, because cross-border investment tax is decided at the level of the individual security.
Both Systems, One Calculation
US and UK advisers on the same file means gains, credits, and elections are computed against both regimes at once, not reconciled after the fact.
Prevention Over Cleanup
A pre-purchase check costs minutes; unwinding a PFIC or a non-reporting fund costs real money. We'd rather review the trade before you make it.
Fixed, Transparent Pricing
Portfolio complexity shouldn't mean open-ended hourly billing. You get a fixed quote up front covering both jurisdictions.
"I'd built what I thought was a sensible index portfolio, and it turned out half of it was PFICs. They quantified the damage, made the right elections, and rebuilt everything with funds that work in both countries. My returns are now boring, which is exactly what I wanted."
Cross-Border Investment Tax Questions
Common questions from investors with assets and accounts in both the US and the UK.
Two Tax Systems, One Team
Email Us
hello@usukcrossbordertax.comLondon Headquarters
4 Crown Place
London EC2A 4BT
United Kingdom
Manchester
CORE
Brown St, Manchester M2 1DH
United Kingdom
San Francisco
600 California St
San Francisco, CA 94108
United States
New York
33 Irving Pl
New York, NY 10003
United States