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Anyone split their time between US and UK?

dan m

dan m

pfm Member
There's a good chance I'll be working 60% US and 40% UK in the future (different employers). Anyone here in a similar position and can provide advice? Frankly, it's looking like a tax/insurance nightmare, but apart from that, I very excited about the opportunity to work both places. Just want to avoid the obvious pitfalls...
 
I've split my time between France and UK in the past, that's hard enough. As for flying across the Atlantic 2 or 3 times a month, no thanks.
 
Dan I have just completed a couple of split years between the US and UK and completed UK and US taxes largely myself. You can PM me if needed.

The US federal side of this is actually easier than the UK since the US taxes your worldwide income regardless of where you are living and working, and then you claim a foreign tax credit for taxes paid to foreign governments. So you just file with your US and UK income combined, converted to dollars, and use form 1116 to claim a foreign tax credit for any UK income taxes paid (but not national insurance). The US state part is the one to be wary of because you might meet full year residency and be double taxed by your state on your UK income - fortunately state income taxes are usually low - California being the notable exception.

It's the UK part that I think will be more complex because if you're continuously going back and forth you won't be able to claim split year treatment. I think you'll need a competent UK tax adviser for this. Mine was easy because I was in the UK continuously for about 14 months so I could file two split year tax returns. If you're going back and forth over multiple years I don't think they allow this and it seemed to me to get quite complicated with counting how many days in the UK etc etc.

The other thing to consider is healthcare. I suspect you'll end up paying US health insurance all year because you may not qualify for the NHS (or at the least there may be gaps in coverage) and you can avoid the ACA penalties. I didn't look into worldwide health insurance so can't help there. We went straight from US insurance to the NHS and back to US insurance but again I'm not sure you can reliably do this if going back and forth. Getting US insurance on can also be complicated because many insurers will not sell a policy without a US address, but of course you can't arrive in the US and get an address without having health insurance (or risk bankruptcy if you get sick/injured shortly after arriving). A friendly insurance agent gave me some tips to get around this - in the end my US employer put me on their insurance before we arrived back in the US.

You could ask your prospective employers to see if they can cover the cost of having a tax accountant do your UK return since I think it will be complex (and expensive).
 
Congrats' Dan. Sounds like a fantastic opportunity that you are carefully thinking through.
 
stevec67 said:
I've split my time between France and UK in the past, that's hard enough. As for flying across the Atlantic 2 or 3 times a month, no thanks.
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It's more like two large continuous blocks per year, so not too crazy with travel. I'm over to see my Dad about once per year anyway, so it really only adds one transatlantic flight.
 
David and Sean - the tax aspects are what scares me. Professional advice will be sought. Yes, I'll be keeping my US health insurance year round - that alone will end up costing me $4K extra.

Thanks, Still - it is a fantastic opportunity I just could not pass up, but does have it's costs, and not just financial.
 
Be very careful and get professional advice on tax and retirement, as no two personal situations are the same. Try to get one or both of your employers to pay for it.
 
PsB - what is the best way to find an independent tax and retirement professional in the UK? I'm little wary of google search results, and since it's a bit of a unique situation, local references of pros with relevant experience are going to be difficult to find.
 
Always carry a gun, and nevercall the cops. Stock up on bullet proof vests. Remember you are living in the evil empire, Trump's travesty of Dodge city.
 
Could you form a company that employees you in your home country and then contracts you out to the companies in the US and the UK, you would continue to be an employee in your home country and so only have one set of employment law to deal with (I think).
 
I was thinking along the same lines - you could go to incorporate a consultancy and 'bill' both organisations for your time. The corporate entity can be located anywhere convenient (like the UK) and the US company can easily pay a foreign invoice - even in Sterling. Your entity can buy whatever health insurance you need for the US. Keeps all the finance in one place - much easier for tax payments, pension contributions and planning. It also allows you to regulate your own personal payments to yourself as needed. You can also employ your wife in the consultancy - admin, invoicing etc.

As ever proper professional advice needed - but I would think this is readily available in any sizable town.
 
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