Who we help
Cross-border tax for landlords & property investors
If you own rental property and have a foot in both the US and UK tax systems, your rent is reportable on both sides — to HMRC through Self Assessment and to the IRS on Schedule E — but double taxation is usually avoidable through the Foreign Tax Credit. The real risks are US depreciation recapture, Section 988 mortgage currency gains, and mismatched expense rules. We coordinate both returns so nothing is missed.
Rental property is one of the most common reasons a cross-border tax position turns complicated. The same property is taxed by HMRC and the IRS, but on different figures, under different rules, and on different timelines — and the two systems do not automatically talk to each other.
Double taxation is usually avoidable; the surprises are not, unless you plan for them. US depreciation that the UK doesn’t recognise, a recapture charge on sale with no UK tax to credit against it, a Section 988 currency gain on a remortgage — these are the issues that catch landlords out, and the ones we get right by handling both returns together.
We help landlords who are…
- US citizens letting UK residential or buy-to-let property
- Brits in the US still holding a UK rental
- Holding property personally or through a UK limited company
- Facing a sale and worried about US capital gains or recapture
- Remortgaging and unsure about currency-gain exposure
- Wanting one team for the UK and US sides of the same property
What you'll likely need
The services that fit your situation
US Tax Returns
Federal and state filing for Americans abroad, done right and on time.
Learn moreFBAR & FATCA
Foreign account and asset reporting kept fully compliant.
Learn moreUK Self Assessment
Self-employed, landlord and high-earner returns to HMRC.
Learn moreTreaty & Tax Planning
Structure income and assets to avoid double taxation.
Learn moreCross-Border Tax Planning
Coordinate income and reliefs across both systems before you file.
Learn moreFrequently asked questions
It is taxed in both systems, but rarely twice. You report the rent to HMRC through Self Assessment and to the IRS on Schedule E, then the Foreign Tax Credit generally offsets the US tax with the UK tax already paid. The complication is that the US requires you to depreciate the property and applies its own rules for allowable expenses, so the taxable figures rarely match between the two returns.
US rules require you to depreciate a rental property each year, reducing your taxable rental income. When you sell, that depreciation is "recaptured" and taxed at up to 25% — even if you never knowingly claimed it, because the US treats it as taken regardless. Many landlords are caught out because the UK has no equivalent, so there is often no UK tax to credit against the US recapture charge.
If rent flows through a UK bank account and your foreign accounts together exceed $10,000 at any point in the year, that account is reportable on the FBAR. Property held through a UK company adds further US reporting, which is why structure matters before you buy.
Yes. Under Section 988, repaying or refinancing a sterling mortgage can create a US-taxable foreign-exchange gain if the dollar strengthened since you borrowed — taxed as ordinary income, with no UK equivalent. It is one of the least-known traps for US-citizen landlords in the UK, and one we plan for directly.
Own property across the Atlantic?
Book a consultation and we'll map your UK and US property tax position in one conversation.