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The US–UK tax glossary

Two systems, two vocabularies. Each term below is explained in plain English — with its closest counterpart on the other side of the Atlantic, because that’s usually the question that matters.

1040US
The US individual federal income tax return. US citizens and Green Card holders generally file one annually on worldwide income, wherever they live.↔ UK: Self Assessment return (SA100)
Self AssessmentUK
The UK system for reporting income HMRC doesn't already tax at source. Filed online by 31 January after the tax year ends.↔ US: Form 1040
FBAR (FinCEN 114)US
An annual report of non-US financial accounts, required when their combined highest balances exceed $10,000. Filed with FinCEN, separately from the tax return.↔ UK: no direct equivalent
FATCA / Form 8938US
A tax-return disclosure of specified foreign financial assets above thresholds that depend on residence and filing status — on top of, not instead of, the FBAR.↔ UK: no direct equivalent
FEIE (Foreign Earned Income Exclusion)US
An election allowing qualifying Americans abroad to exclude a capped, inflation-adjusted amount of foreign earned income from US tax (Form 2555).↔ Alternative: Foreign Tax Credit
Foreign Tax CreditBoth
A credit for tax paid to the other country on the same income — the main mechanism preventing double taxation. Claimed on Form 1116 in the US; via the foreign pages in Self Assessment.↔ Both systems, mirrored
US–UK tax treatyBoth
The bilateral convention allocating taxing rights between the two countries — vital for pensions, Social Security, dividends and residency tie-breakers. Some positions must be disclosed on Form 8833.
Statutory Residence Test (SRT)UK
The day-count and ties-based test that determines UK tax residence for a tax year.↔ US: citizenship/Green Card taxation, or the Substantial Presence Test for others
Substantial Presence TestUS
The day-count test that can make a non-citizen a US tax resident based on time physically spent in the US over three years.↔ UK: Statutory Residence Test
FIG regime (foreign income & gains)UK
The regime that replaced the remittance basis from 6 April 2025: qualifying new UK arrivals can claim relief on foreign income and gains for their first four years of residence.↔ US: no equivalent — worldwide taxation from day one
Split-year treatmentUK
Rules that can divide a UK tax year into resident and non-resident parts in the year you arrive or leave, when conditions are met.↔ US: dual-status return
Dual-status returnUS
A US return covering a year in which someone was a US tax resident for part of the year and a non-resident for the rest — common in Green Card arrival/departure years.↔ UK: split-year treatment
ISAUK
A UK tax-free savings/investment wrapper. The US does not recognise the wrapper: income and gains inside an ISA are taxable to US persons, and funds held inside can be PFICs.↔ US: no true equivalent (Roth IRA is the loose analogue)
PFICUS
Passive Foreign Investment Company — the punitive US regime that catches most non-US funds and ETFs, taxing gains at unfavourable rates with dense reporting on Form 8621.↔ UK mirror-image: non-reporting offshore funds
HMRC reporting fundUK
A non-UK fund with HMRC reporting status, keeping gains within capital gains treatment for UK investors. The UK's mirror image of the PFIC problem — US-domiciled funds without this status are penalised in the UK.↔ US: PFIC rules
401(k)US
A US employer-sponsored retirement plan funded from pre-tax salary.↔ UK: workplace pension
IRA / Roth IRAUS
US individual retirement accounts — traditional (pre-tax, taxed on withdrawal) and Roth (post-tax, tax-free growth and qualified withdrawals). Treaty treatment in the UK differs between them.↔ UK: SIPP (loosely); no true Roth equivalent
SIPPUK
Self-Invested Personal Pension — a personal UK pension with investment control. Its US treatment raises genuine technical questions, from treaty relief to trust-reporting exposure.↔ US: IRA (loosely)
State PensionUK
The UK's contributions-based government pension.↔ US: Social Security
Social SecurityUS
The US government retirement and disability system. Under the treaty, US Social Security paid to a UK resident is generally taxable only in the UK.↔ UK: State Pension
Totalization agreementBoth
The US–UK social security agreement preventing double social-security contributions and helping combine contribution records across both countries.
Streamlined Foreign Offshore ProceduresUS
The IRS programme letting non-wilful late filers abroad catch up — generally three years of returns and six years of FBARs — with the usual failure penalties waived.↔ UK: voluntary disclosure via HMRC
Payments on accountUK
Advance payments towards the current year's UK tax bill, due 31 January and 31 July, based on last year's liability.↔ US: quarterly estimated taxes
Estimated taxesUS
Quarterly prepayments of US tax where withholding won't cover the bill — commonly needed by self-employed expats.↔ UK: payments on account
Capital gains tax (CGT)Both
Both countries tax gains, but with different rates, exemptions, and — crucially — different currencies: the US computes gains in dollars, so exchange-rate movement alone can create a taxable US gain.
IHT (Inheritance Tax)UK
UK tax on estates and some lifetime gifts, now based on long-term residence rather than domicile.↔ US: federal estate & gift tax (with a far larger exemption)
GILTIUS
A US anti-deferral regime that can tax US owners of controlled foreign companies — including a one-person UK limited company — on the company's profits as they arise.↔ UK: no equivalent for individuals
Form 5471US
The detailed US information return often required from US persons who own significant stakes in non-US companies, such as a UK Ltd. Heavy penalties for non-filing.↔ UK: no equivalent for individuals
Accidental AmericanUS
Someone with US citizenship — usually by birthplace or parentage — who has lived their life elsewhere and often only discovers their US tax obligations decades later.
Payment on 60-day reportUK
UK residential property sales with tax due must be reported and the CGT paid within 60 days of completion — separate from, and earlier than, Self Assessment.↔ US: reported on the annual 1040

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