US and UK Tax Specialists for American Citizens: Creator’s Guide

US and UK Tax Specialists for American Citizens: Creator’s Guide

Mastering Taxes with US and UK Tax Specialists for American Citizens

Filing taxes in one country can feel overwhelming. Filing them in two—like the United States and the United Kingdom—can seem impossible. For American creators living or working in the UK, understanding the tax requirements of both the UK and the US is essential. Mistakes can lead to double taxation, late penalties, or, worse, unclaimed refunds. That’s why US and UK tax specialists for American citizens play a vital role. These experts help you file compliant, accurate, and optimised tax returns that meet both IRS and HMRC standards. Whether you’re a YouTuber earning ad revenue from California or a digital artist living in London, proper tax planning prevents costly errors and maximises your earnings.

At JungleTax, we’ve seen how American content creators in the UK often struggle with cross-border rules. This guide simplifies the process, so you can understand what to file, when to file, and how to avoid paying more than you owe.

Understanding the Dual Tax Obligation

As a U.S. citizen, you are required to report your worldwide income to the IRS, regardless of your place of residence. At the same time, if you reside or work in the UK, HMRC also expects a report of your earnings.

This dual obligation confuses many expats and creators. The United States taxes based on citizenship, while the UK taxes based on residency. If you’re earning through brand deals, royalties, or partnerships in both countries, you need precise coordination to avoid being taxed twice.

US and UK tax specialists for American citizens help align both systems using tools such as the Foreign Earned Income Exclusion (FEIE), the Foreign Tax Credit (FTC), and double taxation relief under the UK treaty.

Step 1: Determine Your Tax Residency

Your first step is understanding where you are considered a tax resident. The UK uses a Statutory Residence Test (SRT) based on time spent in the country and your personal ties. If you live in the UK for over 183 days in a tax year, you’re likely a UK resident for tax purposes.

Meanwhile, the US automatically considers you a tax resident as long as you hold citizenship. This creates overlapping tax responsibilities. A qualified accountant helps you declare income correctly in both jurisdictions and apply relevant treaty provisions.

For example, a US-born influencer living in Manchester may pay UK tax on YouTube partnership earnings but can claim credits on their US return to offset those payments.

Step 2: Report Worldwide Income Accurately

Creators earn income in many ways—sponsorships, ad revenue, affiliate marketing, and digital products. You must report all of these earnings to both the IRS and HMRC.

US and UK tax specialists for American citizens ensure each income stream is categorised under the correct tax heading. This prevents confusion when your US and UK accountants prepare returns in different formats.

For instance, if you earn £80,000 through your UK-based company and $10,000 from US sponsors, both figures require conversion and reporting on each return, adjusted by currency exchange rates.

Step 3: Avoid Double Taxation through Treaties

The double taxation relief UK treaty exists to prevent you from paying tax on the same income twice. It allows you to offset tax paid in one country against tax paid in another.

For most American creators, this means if you’ve paid income tax in the UK, you can claim those payments as credits on your US return through the Foreign Tax Credit (Form 1116). Alternatively, if you qualify under the Foreign Earned Income Exclusion, you can exclude up to a set amount of your foreign income from US taxation entirely.

JungleTax often helps clients determine which option offers greater benefit, based on income structure, business type, and residency duration.

Step 4: Understand Self-Employment and Business Rules

If you operate as a freelancer or limited company, your reporting requirements differ.

  • Self-Employed Creators: You must register with HMRC, pay income tax, and make National Insurance contributions. The IRS also requires Schedule C reporting for self-employment income.

  • Limited Company Directors: You’ll file UK corporate returns with HMRC and report dividends to the IRS as foreign income.

For creators running multi-channel businesses, having US and UK tax specialists ensures that both systems consistently recognise your structure.

A YouTuber running a personal brand agency, for example, may pay UK corporation tax while reporting corresponding dividends to the US under the foreign income category.

Step 5: Track Foreign Bank Accounts and Assets

The IRS requires American citizens to disclose overseas financial accounts under the Foreign Bank Account Report (FBAR) and FATCA rules. Failure to do so can result in hefty penalties.

If your UK accounts hold more than $10,000 at any point during the year, you must file an FBAR. Similarly, UK investments, pensions, or savings accounts may be subject to FATCA reporting.

At JungleTax, we help creators maintain accurate records and file disclosures on time.

Step 6: File US and UK Tax Returns on Time

The UK tax year runs from April 6 to April 5, while the US tax year aligns with the calendar year. This mismatch often confuses creators filing in both systems.

Deadlines:

  • UK: January 31 (online filing for the previous tax year)

  • US: April 15 (extended to June 15 for Americans abroad)

US and UK tax specialists for American citizens coordinate both filings to ensure no overlap or missed reporting. They also help you request extensions if income verification takes longer due to cross-border activity.

Step 7: Claim Every Available Deduction

Creators can deduct business-related expenses in both countries. These include:

  • Production costs (equipment, lighting, software)

  • Travel and accommodation for brand shoots

  • Professional services such as accountants, editors, or agents

  • Marketing and digital subscriptions

For example, you run an online channel and purchase a camera or editing software. In that case, you can claim it as a business expense in both jurisdictions—while ensuring you don’t double-deduct. JungleTax ensures expenses are categorised correctly for each country’s tax system.

Step 8: Maintain Proper Records Year-Round

Cross-border creators should maintain detailed accounting records throughout the year to ensure accurate financial reporting. Digital invoices, receipts, and transaction logs simplify both IRS and HMRC submissions.

JungleTax recommends using cloud-based accounting tools to automate expense tracking, conversions, and categorisation. These tools integrate with both UK and US tax software, enabling faster, error-free filing.

Step 9: Consider Incorporating for Tax Efficiency

Some creators benefit from forming a UK limited company or a US LLC for tax efficiency purposes. This structure enables controlled salary withdrawals, dividend planning, and improved expense management.

However, incorporation decisions depend on your income, residency, and long-term goals. US and UK tax specialists for American citizens can assess whether incorporation aligns with your overall financial strategy.

Real-Life Example: How JungleTax Helped an American Creator

Samantha, a Los Angeles-born podcaster living in Bristol, earned income through YouTube ads, Patreon memberships, and sponsored collaborations. She faced confusion over double taxation, receiving notices from both the IRS and HMRC.

JungleTax reviewed her financials, restructured her reporting, and applied the UK treaty provisions on double taxation. The result: her US tax bill was reduced by 70%, and she avoided penalties. Now, she files seamlessly through our coordinated system—saving time, money, and stress.

Why Work with JungleTax?

At JungleTax, we specialise in complex tax filings for creators, influencers, and entrepreneurs living between the UK and the US. Our US and UK tax specialists for American citizens handle compliance, planning, and optimisation—so you can focus on your craft.

We understand the unique income streams of digital creators and align them with cross-border rules to ensure accuracy and savings.

For expert help with your taxes, contact JungleTax today at hello@jungletax.co.uk or call 0333 880 7974.

FAQs

Do American citizens in the UK need to file US taxes?

Yes, all US citizens must report their global income to the IRS, even if they live abroad.

What is the double taxation relief in the UK?

It’s a treaty that allows Americans in the UK to offset taxes paid in one country against taxes paid in the other, thereby preventing double taxation.

Can creators deduct business expenses in both countries?

Yes, but only once per item. A cross-border accountant ensures the proper allocation of resources between jurisdictions.

What happens if I miss my FBAR filing?

 Late FBAR filings can lead to significant fines. JungleTax helps ensure timely and accurate submissions.

How can JungleTax assist American creators in the UK?

Our experts simplify US-UK filing, claim double-taxation relief, and help creators optimise deductions legally and efficiently.