Can I use my UK P60 figure as my wages on Form 1040?

Not directly. A P60 covers the UK tax year from 6 April to 5 April, while Form 1040 covers the calendar year. Each US year must be rebuilt from two UK tax years, usually by subtracting the December payslip year-to-date figures from the March year-to-date figures and adding the next year's April to December figures. The P60 remains useful as a control total that your calendar-year slices must reconcile back to.

How do I get old UK payslips or P60 figures if my employer portal is closed?

Ask the employer's payroll or HR team first, as GOV.UK advises for replacement P60s. Your HMRC personal tax account shows income from work and Income Tax paid for the previous 5 years, and the HMRC app can provide P60 information. Those tax-year totals work as control figures, but you still need month-level year-to-date reports from the employer to split each year.

Which exchange rate should I use to convert UK salary to US dollars?

The IRS says it has no official exchange rate and generally accepts any posted rate used consistently. It publishes yearly average rates on irs.gov, which are commonly used for evenly paid salary, while the general rule is the spot rate on the date an item is received. A large one-off bonus may justify a spot rate. Record the rate source and date in your workpaper.

Can I claim both the foreign earned income exclusion and a foreign tax credit?

You can use both on one return, but not on the same income. IRS Publication 514 states you cannot take a credit or deduction for foreign taxes paid on income excluded under the foreign earned income exclusion. For high earners, the exclusion limit covers only part of the salary, so the foreign tax credit on Form 1116 is often more valuable. Model both before choosing.

Is UK National Insurance creditable against US tax?

Generally not. IRS Publication 514 treats social security taxes paid to a country that has a social security agreement with the US as not creditable, and the UK has such an agreement. Only UK income tax, whether deducted through PAYE or paid through Self Assessment, should go on Form 1116. Keep National Insurance on its own line in your reconciliation so it is excluded cleanly.

How many years of US returns do I need if I have been working in the UK?

Under the Streamlined Foreign Offshore Procedures, the IRS requires the most recent 3 years of delinquent or amended tax returns and the most recent 6 years of FBARs, plus a non-willful certification. Three US years need four UK tax years of payroll records, because each US year spans two UK years. Longer look-back periods can apply outside the streamlined procedures.

Missed US Tax Returns: Rebuild Wages From UK P60s

Missed US tax returns for years spent employed in the UK can be rebuilt accurately, but not by copying P60 totals onto a Form 1040. A P60 covers the UK tax year from 6 April to 5 April, while a US return covers the calendar year from 1 January to 31 December, so every US year you file has to be assembled from two UK tax years using the year-to-date figures on your monthly payslips. Once the wage and UK tax figures are rebuilt for each calendar year, they are converted to US dollars and used to claim either the foreign tax credit on Form 1116 or the foreign earned income exclusion on Form 2555.

This guide is written for the profile we see most often in catch-up filings: a US citizen working in London or elsewhere in the UK as a banker, fund professional, executive or senior partner-track employee, paid through UK PAYE, who assumed that because UK tax was deducted at source there was nothing left to do in the US. In the returns we prepare for these clients, the tax is rarely the hard part. The hard part is producing clean, defensible calendar-year numbers from documents that were designed around a different year end.

Why can a P60 never be copied straight onto a Form 1040?

A P60 is the end-of-year certificate a UK employer gives to employees who are still working for it at the end of the tax year. GOV.UK explains at https://www.gov.uk/paye-forms-p45-p60-p11d that the P60 shows the tax you have paid on your salary in the tax year running 6 April to 5 April, and that employers must provide it by 31 May. That date window is the whole problem. The P60 for 2024/25, for example, contains nine months of pay that belong on a 2024 US return (April to December 2024) and three months that belong on a 2025 US return (January to March 2025).

If you drop that P60 figure onto one Form 1040, you misstate two years at once. For a salaried employee with flat pay the error can look small, but for high earners it rarely is. Bonuses in the City are very often paid in the first quarter of the calendar year, which is also the last quarter of the UK tax year. A March bonus sits inside the P60 for the UK year ending that April, but for US purposes it belongs to the calendar year in which it was paid. Copy the P60 across and the bonus can land in the wrong US year, pulling the foreign tax credit, the exchange rate and potentially the streamlined penalty base out of line with it.

A short note on a form we are often asked about: US Form 4852 is a substitute for a missing US Form W-2 and is almost never the right document for UK PAYE income, because a UK employer is not a US withholding agent. We cover that in a separate article. For UK employment, the source documents are the UK ones described below, reported as foreign wages.

What does each UK payroll document actually show?

Before rebuilding anything, it helps to be precise about what each UK document is and is not. The GOV.UK guidance at https://www.gov.uk/paye-forms-p45-p60-p11d describes three documents an employee may receive, and each plays a different role in a US reconstruction.

P60: the annual certificate for employees still in the job on 5 April. It summarises taxable pay and income tax deducted for the whole UK tax year, which makes it a control total, not a US figure.
P45: issued when you leave an employer. It records pay and tax from the start of the UK tax year up to your leaving date, which makes it essential in any year where you changed jobs, because the P60 from the new employer will not include pay from the old one.
P11D: submitted by the employer where you received benefits in kind, such as a company car or an interest-free loan. GOV.UK notes that if the employer taxes those benefits through payroll, a P11D may not be needed, and that you can ask your employer for a record of what was reported and what each benefit was worth.
Monthly payslips: the only documents that show pay month by month, with year-to-date totals that reset at the start of each UK tax year. These are the raw material for calendar-year figures.

A useful citable definition: a calendar-year wage reconstruction is a workpaper that converts UK tax-year payroll records into January-to-December figures for gross pay, taxable pay, pre-tax deductions, benefits and UK tax withheld, reconciled back to each P60 and P45.

How do you split a UK tax year using payslip year-to-date figures?

UK payslips usually show two sets of numbers: the amounts for the pay period and the cumulative totals for the tax year to date. The year-to-date columns are the key to an efficient rebuild, because you rarely need all twelve payslips for a year. You need the right ones.

Step 1: For each UK tax year that touches a US year you are filing, obtain the final payslip before 31 December (typically the December payslip, month 9 of the UK tax year). Its year-to-date figures give you April to December pay and tax.
Step 2: Obtain the final payslip of the UK tax year (the March payslip, month 12). Its year-to-date figures should match the P60 for that year. If they do not, find out why before going further.
Step 3: January to March pay equals the March year-to-date figure minus the December year-to-date figure. Do the same subtraction for tax deducted and for each pre-tax deduction line.
Step 4: The US calendar-year figure equals January to March of the earlier UK tax year plus April to December of the later UK tax year.
Step 5: Repeat for every column you need: gross pay, taxable pay, pension or salary sacrifice deductions, benefits processed through payroll, income tax and National Insurance.

Where your employer changed payroll provider mid-year, or you moved employer, the year-to-date figures may restart or be split across two payroll records. In that case you work from the P45 and the new employer's payslips separately and combine them, rather than relying on one running total.

Worked example: rebuilding calendar year 2025 from two UK tax years

The following figures are an illustration only. They are invented to show the mechanics, they are not a UK tax computation, and the exchange rate used is an assumption, not a published IRS rate. Assume a US citizen employed by a London bank on basic salary of 20,000 pounds a month for UK tax year 2024/25, rising to 21,000 pounds a month from April 2025. She sacrifices 1,500 pounds a month of salary into the employer pension scheme. A bonus of 90,000 pounds was paid in March 2025 and a bonus of 110,000 pounds in March 2026. She has missed US tax returns for 2023, 2024 and 2025, and we are rebuilding 2025.

Line A, 2024/25 P60 (matches the March 2025 payslip year-to-date): taxable pay 312,000 pounds, made up of 12 months at 18,500 pounds after salary sacrifice plus the 90,000 pound bonus. Illustrative UK tax deducted: 118,400 pounds.
Line B, December 2024 payslip year-to-date (months 1 to 9 of 2024/25): taxable pay 166,500 pounds. Illustrative UK tax deducted: 61,100 pounds.
Line C, January to March 2025 (Line A minus Line B): taxable pay 145,500 pounds, including the 90,000 pound bonus. UK tax deducted: 57,300 pounds.
Line D, December 2025 payslip year-to-date (months 1 to 9 of 2025/26): taxable pay 175,500 pounds (9 months at 19,500 pounds after sacrifice). Illustrative UK tax deducted: 70,200 pounds.
Line E, calendar 2025 UK taxable pay (Line C plus Line D): 321,000 pounds. UK tax withheld in calendar 2025: 127,500 pounds.
Line F, salary sacrifice in calendar 2025: 3 months at 1,500 pounds plus 9 months at 1,500 pounds, 18,000 pounds in total, held on a separate line for the US treatment decision discussed below.
Line G, gross cash earnings before sacrifice for calendar 2025: 339,000 pounds (Line E plus Line F).
Line H, conversion at an assumed rate of 0.78 pounds per dollar, used here purely for illustration: taxable pay of 321,000 pounds is about 411,538 dollars, gross earnings of 339,000 pounds is about 434,615 dollars, and UK tax of 127,500 pounds is about 163,462 dollars.

Notice what the P60 approach would have done. Copying the 2024/25 P60 into 2025 would report 312,000 pounds instead of 321,000 pounds of taxable pay, and 118,400 pounds instead of 127,500 pounds of UK tax, and it would leave nothing sensible for the 2024 return, because the April to December 2024 pay sits on that same P60 and one P60 cannot be used for two US years. The 2026 bonus, meanwhile, will sit on the 2025/26 P60 but belongs on the 2026 US return, which is outside this filing set entirely if 2026 is not yet due.

Where do you find missing payslips and past-year figures?

Most senior employees can download historic payslips from an employer self-service portal, but portals are often switched off when you leave, and payroll systems get replaced. When documents are missing, work through the sources in this order.

Your employer or former employer's payroll or HR team. GOV.UK says to ask your employer first for a replacement P60, and employers can usually reissue payslips or produce a year-to-date report at any month end on request.
Your HMRC personal tax account. GOV.UK confirms at https://www.gov.uk/personal-tax-account that the account lets you check your income from work and the Income Tax you paid in the previous 5 years. That gives you tax-year totals per employer, which are ideal as control figures even though they do not split the year.
The HMRC app, which GOV.UK lists alongside the personal tax account as a way to get P60 information if your employer cannot replace it.
HMRC directly, if neither the employer nor the online account can provide what you need.
Bank statements, as a last resort for monthly net pay. Net pay alone cannot be reverse-engineered into gross pay and tax with confidence, so we use it only to corroborate, never as the primary source.

Because the personal tax account shows tax-year totals rather than monthly splits, a common practical fix is to ask the employer for just two reports per UK tax year: year-to-date at 31 December and year-to-date at 5 April. Those two reports, reconciled to the HMRC record, are enough to rebuild the calendar year.

How are salary sacrifice and UK pension contributions treated on a US return?

UK payslips reduce taxable pay for pension contributions made through salary sacrifice or net pay arrangements, and the P60 figure is shown after those reductions. The US does not automatically follow UK payroll treatment. Whether some or all of those contributions can be kept out of US wages depends on the US-UK income tax treaty pension provisions, the type of scheme, and the facts of the individual, and it is a point we decide on a return-by-return basis rather than by default.

The practical rule for the reconstruction is simple: always capture gross pay before salary sacrifice as well as UK taxable pay, as in Line F and Line G of the example above. That way the US wage figure can be set correctly once the treatment is decided, without going back to the payslips. The failure mode we see most often in self-prepared returns is reporting UK taxable pay after sacrifice as US wages without ever considering the question, which can understate US income. The opposite error, adding sacrifice back and also claiming a treaty exclusion elsewhere, double-counts the adjustment.

Other pre-tax lines on UK payslips deserve the same treatment. Cycle-to-work schemes, share plan deductions and similar arrangements should each sit on their own line in the workpaper so the US position can be taken deliberately. Share awards and employee share plans raise their own timing and sourcing questions and usually need a separate schedule.

How do bonuses and benefits in kind fit into the calendar year?

For a cash-basis individual, a bonus is generally reported in the US year in which it is paid, so the payslip month matters more than the performance year the bonus relates to. In the worked example, the March 2025 bonus belongs to 2025 even though the bank may describe it as a 2024 bonus. If a bonus was paid in April, it falls into both a new UK tax year and the same US year as the preceding January to March pay, which can make a single calendar year look unusually heavy. That is expected, not an error.

Benefits in kind such as private medical insurance, company cars or beneficial loans are reported to HMRC either through payroll or on the P11D. When they are payrolled, the value appears on payslips and flows into the year-to-date figures automatically. When they are reported on a P11D, the amount is an annual figure for the UK tax year and has to be apportioned into calendar years, usually on a time basis unless the benefit was provided on specific dates. Keep the P11D, or the employer's written record of it, with the workpaper.

How do you convert pounds to dollars for missed US tax returns?

Every amount on a US return must be in dollars. The IRS page at https://www.irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates states that the IRS has no official exchange rate and generally accepts any posted exchange rate that is used consistently. It also says that, in general, you use the rate prevailing (the spot rate) when you receive, pay or accrue an item, and it publishes yearly average rates that many filers use for income received evenly through the year. To convert, you divide the foreign currency amount by the yearly average rate shown in the table.

For regular monthly salary, a yearly average rate is widely used and simple to defend. For a large bonus paid on a single date, a spot rate for the payment date can give a materially different answer, particularly in a year when sterling moved sharply. Whichever approach you choose, the key is consistency across the return and a note in the workpaper recording the source and date of every rate. Foreign taxes have their own translation rules, covered in the next section, and FBAR maximum values use a separate Treasury rate, not the IRS yearly average table.

Form 1116 or Form 2555: where does the UK PAYE tax go?

Once the calendar-year figures exist, you choose how to prevent double taxation. The foreign earned income exclusion, claimed on Form 2555 and explained at https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion, excludes foreign earned income up to an annual inflation-adjusted limit. For the salary levels in this article, the limit covers only part of the pay. Crucially, IRS Publication 514 at https://www.irs.gov/publications/p514 states that you cannot take a credit or a deduction for foreign taxes paid on income you exclude under the foreign earned income exclusion. The UK tax attributable to the excluded slice is simply lost for credit purposes.

The foreign tax credit on Form 1116 instead credits the UK income tax against the US tax on the same income. Because UK rates on high earners are generally higher than the effective US rate on the same wages, most UK-employed bankers and executives we prepare returns for end up with no US tax on their wages and excess credits to carry, and the credit route is usually the one we model first. The right answer still depends on the whole return, including investment income, and both routes should be modelled.

Two practical points about the UK tax figure itself. First, only income tax belongs in the credit. Publication 514 treats social security taxes paid to a country with which the US has a social security agreement as not creditable, and the US has such an agreement with the UK, so UK National Insurance deducted on payslips stays out of Form 1116. Second, if you file UK Self Assessment returns, balancing payments and payments on account are additional UK income tax paid outside payroll and must be brought into the calendar-year tax schedule on the dates they were paid, or on an accrual basis if that choice applies.

Cash or accrual: which year does the UK tax belong to?

The IRS explains at https://www.irs.gov/individuals/international-taxpayers/foreign-tax-credit-choosing-to-take-credit-or-deduction that a cash-method individual can claim the credit in the year the tax is paid, or can choose to claim it in the year the tax accrues by checking the box in Part II of Form 1116. Publication 514 adds that once you make the accrual choice, you must follow it in all later years.

On the cash method, UK PAYE tax is credited in the calendar year it was withheld, which is exactly what the payslip reconstruction produces: in the example, 127,500 pounds for 2025. Publication 514 says tax withheld in foreign currency is translated at the rate for the date it was withheld, so a cash-basis credit strictly needs the monthly withholding figures and monthly rates, another reason to keep the month-level workpaper. On the accrual method, the timing follows the year the UK liability accrues, and Publication 514 generally requires accrued taxes to be translated at the average exchange rate for the tax year to which they relate, subject to conditions. Because the UK liability is fixed by reference to the UK tax year, the accrual choice can shift tax between US years in ways that are not intuitive, and because the choice is binding going forward, it is one we model across the whole filing set before committing to it, rather than year by year.

How many years of missed US tax returns need to be rebuilt?

For UK residents whose failure to file was non-willful, the usual route is the Streamlined Foreign Offshore Procedures. The IRS page at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states requires delinquent or amended tax returns for the most recent 3 years for which the due date has passed, and delinquent FBARs for the most recent 6 years, together with a non-residency test and a non-willful certification. For three US tax years you therefore need four UK tax years of payroll records, because the first and last US years each borrow from a UK year outside the three.

Outside the streamlined procedures, the look-back can be longer, and IRS delinquent-return practice often refers to a six-year period, so the records you gather should extend beyond the minimum where they are available. The IRS page at https://www.irs.gov/businesses/small-businesses-self-employed/filing-past-due-tax-returns also notes that a refund claim for a past year must be made within 3 years of the return due date. Late FBARs themselves are filed electronically through FinCEN's BSA E-Filing System at https://bsaefiling.fincen.treas.gov with a reason for late filing, or as part of a streamlined submission; the IRS withdrew its separate Delinquent FBAR Submission Procedures page in 2026 and it should not be treated as a live route.

The most common errors in UK payslip reconstructions

Using P60 totals as calendar-year wages, which misplaces three months of pay in every year and can move entire bonuses into the wrong US year.
Double-counting bonus months, typically by taking the P60 for one year and then adding a March bonus again from a payslip because it looked large.
Reporting UK taxable pay after salary sacrifice as US wages without deciding the US treatment, or adding the sacrifice back and also claiming treaty relief elsewhere.
Missing a P45 year, so pay from the old employer between 6 April and the leaving date never reaches any US return.
Crediting National Insurance as if it were income tax on Form 1116.
Claiming the foreign earned income exclusion and a foreign tax credit on the same excluded wages.
Mixing exchange-rate methods between years, or between income and tax, without a stated reason.
Leaving out Self Assessment balancing payments, or P11D benefits not taxed through payroll.

What should a reconciliation workpaper contain?

A reconciliation workpaper is the single schedule that proves every wage and tax figure on the US returns ties back to a UK source document. It is the first thing we would expect to rely on if the IRS ever asked how the numbers were derived, and it makes the next year's return straightforward. At minimum it should show, for each UK tax year and each employer, the P60 or P45 totals, the HMRC personal tax account totals, the December and March year-to-date figures, the calculated January-to-March and April-to-December splits, each pre-tax deduction, each benefit, income tax and National Insurance on separate lines, the exchange rate source and date, and the final dollar figures carried to Form 1040, Form 1116 or Form 2555.

A simple test we apply before finalising: for every UK tax year in the set, the two calendar-year slices must add back exactly to the P60, or to the P45 plus the next employer's P60. If they do not tie, something is missing or double-counted, and it is almost always a bonus month or a change of employer.

Getting missed US tax returns filed correctly

UK payroll records are detailed and reliable, which is good news for anyone catching up. The work is in re-cutting them to the US calendar, deciding the treatment of salary sacrifice and benefits, choosing the right exchange-rate approach and matching the UK tax to the right year and the right form. Done carefully, most UK-employed high earners find the reconstruction confirms little or no US tax on their wages, with the real exposure coming from investment income and unfiled information returns rather than salary. If you are behind, our team prepares streamlined submissions, delinquent Form 1040s, Forms 1116 and 2555 and late FBARs for US citizens in the UK, starting from exactly the payslips and P60s described here.