The United States is unique among industrialised nations in
subjecting its citizens to worldwide income and gains tax wherever
they happen to live. Accordingly, Americans living in the UK have
historically faced fewer incentives than nationals of other
countries to elect to use the 'remittance basis' of UK
taxation simply because they face a citizen-based tax
'floor' with which virtually no other country's
citizens are burdened.
The Conservative Government's Spring Budget purports to
eliminate the UK's non-dom regime from 6 April 2025. From an
income and gains perspective, this change will likely worry US
citizens less than the typical UK remittance basis user.
Nonetheless, UK-resident US citizens who have
been relying on the remittance basis thus far will face a
distinctive set of challenges when the non-dom regime comes to an
end. The end of the domicile-based UK inheritance tax
('IHT') regime may pose more immediate concerns for
Americans living in the country
