Can I just report my P60 figure on my US tax return?

No. A P60 covers the UK tax year from 6 April to 5 April, so it spans two US calendar years. Using it unadjusted overstates income in one US year and understates it in the next, and puts the foreign tax credit in the wrong year. Use the P60 as a control total and allocate income by the actual payment dates shown on your payslips and bank statements. You will normally need two consecutive P60s to build one US year.

Do P11D benefits go on my US return?

Yes. Benefits in kind such as private medical cover, a company car, employer paid school fees or a low interest loan are compensation for US purposes and belong in your US wage figure, even though no cash reached your account. GOV.UK confirms employers must report expenses and benefits to HMRC by 6 July. Check first whether your employer payrolls benefits, because if it does, the value is already inside your P60 pay figure and must not be counted twice.

What exactly do I need from my UK bank for the FBAR?

For each account you need the institution's full legal name and address, the account number, the account type, and the maximum value at any point in the calendar year. FinCEN allows reliance on periodic statements issued at least quarterly where they fairly reflect that maximum. Convert using the Treasury Bureau of the Fiscal Service rate for the last day of the calendar year. Include dormant, joint and foreign currency accounts, and any account over which you hold signature authority.

I paid my UK Self Assessment bill in January. Which US year does the credit fall in?

For a cash basis US filer, foreign tax is credited in the year it is paid. A balancing payment made in January 2026 for the UK year ended 5 April 2025 is foreign tax paid in US calendar year 2026. IRS Publication 514 allows an election on Form 1116 to claim credits on the accrual basis instead, but that election cannot be made on an amended return and binds all later years. Keep the HMRC statement of account, which evidences every payment date.

Which UK investments create extra reporting, and what data is needed?

Non US pooled funds, including many UK open ended investment companies, unit trusts, investment trusts and European exchange traded funds held inside or outside an ISA, commonly meet the passive foreign investment company definition and are reported on Form 8621. A platform valuation is not enough. You need the fund's legal name and ISIN, every acquisition and disposal with dates and costs, all distributions, and every reinvested distribution, because each reinvestment creates a separate lot.

What can I do if my old P60s and statements are gone?

Start with your HMRC personal tax account, which shows income from work and income tax paid for the previous five years plus your National Insurance record and UTR. Ask former employers for duplicate P60s or a statement of earnings. Download SA302 calculations and tax year overviews, available for the last four years. Request archived bank statements in writing. Then pull IRS wage and income and tax account transcripts to establish what the IRS already holds.

US Tax Return Preparation for Expats: UK Document Pack

US tax return preparation for expats living in the United Kingdom fails far more often on missing documents than on difficult law. The short answer to what you must assemble before a US return can even be started is this: a complete UK income record covering both halves of the US calendar year, evidence of UK tax actually paid rather than merely assessed, maximum balances for every UK financial account, holding level detail on every UK fund and company shareholding, and one exchange rate source you can apply consistently and defend. Everything else in a cross-border engagement sits downstream of that pack.

The difficulty is structural rather than technical. UK source documents are built around a tax year that runs from 6 April to 5 April, and they are built to satisfy HMRC, not the Internal Revenue Service. A P60 answers a question the IRS never asked. A Self Assessment computation reports on a period that straddles two US filing years. UK platforms report gains on a basis that has no direct US analogue. In the returns we prepare for clients in the City, Mayfair, Edinburgh and the Home Counties, the single largest cause of delay is not the analysis. It is a document pack that was assembled for HMRC and then handed over unchanged.

This guide sets out the pack in the order a preparer genuinely works through it. It explains what each UK document proves, what it silently omits, and which US return line or form it feeds. It then covers the two situations most checklists ignore entirely: how to split a UK tax year across two US calendar years with evidence that survives scrutiny, and what to gather when the paperwork is gone and the years are old.

What Does US Tax Return Preparation for Expats in the UK Actually Require?

US tax return preparation for expats is the process of restating a full year of worldwide income, tax and asset data on US calendar year, US dollar and US characterisation terms. Three conversions happen simultaneously. A period conversion moves data from the UK tax year to the US calendar year. A currency conversion moves sterling to dollars, and the IRS is explicit that amounts reported on a US return must be expressed in US dollars, with items translated using the rate prevailing when you receive, pay or accrue them, as set out at https://www.irs.gov/individuals/international-taxpayers/foreign-currency-and-currency-exchange-rates. A characterisation conversion moves UK income categories onto US ones, which is where UK funds become passive foreign investment companies and UK company shares become controlled foreign corporation reporting. A document is only useful to a preparer if it supports all three conversions.

For a high net worth American in the UK, the working pack breaks into twelve families. Very few clients arrive with more than half of them.

Employment records: every P60, P45, P11D, monthly payslip and any share plan or bonus payment advice, for two consecutive UK tax years
Self Assessment records: the filed SA100 and supplementary pages, the SA302 tax calculation, the tax year overview, and the HMRC statement of account showing payment dates and amounts
Bank and building society records: full year statements and a written maximum balance figure for every account, including dormant and joint accounts
Investment platform records: consolidated tax certificates, holding statements, contract notes and full transaction histories including ISAs
Pension records: annual statements for every workplace scheme, personal pension and self invested personal pension, plus contribution schedules split between employer and employee
Company records: share certificates, the register of members, statutory accounts, Companies House filings and corporation tax computations for any UK company you own or control
Property records: letting agent annual statements, the purchase completion statement, mortgage interest certificates and a record of capital works
Foreign tax evidence: proof of PAYE deducted, Self Assessment payments made and their dates, and any HMRC repayments received
Exchange rate evidence: the rate source you used, applied consistently across the whole return
Residence and travel records: UK arrival and departure dates, a day count, and any split year or Statutory Residence Test analysis
Prior year US records: the last filed federal and state returns, foreign tax credit carryover schedules and prior FBAR filings
Identity and account data: Social Security numbers, the UK Unique Taxpayer Reference, National Insurance number and institution addresses for reporting

What a P60 Gives You and What It Does Not

A P60 is an end of year certificate an employer must give an employee who is still employed at the end of the UK tax year, and GOV.UK confirms at https://www.gov.uk/payroll-annual-reporting that the deadline for giving it to the employee is 31 May. It records total pay and total PAYE income tax deducted for the UK tax year, along with National Insurance information and, where relevant, pay and tax from a previous employment in the same year. It is the closest thing the UK has to a Form W-2, and it is genuinely useful. It is also, on its own, insufficient for a US return.

What the P60 does not give you is the point that matters. It carries no payment dates, so it cannot tell a cash basis US taxpayer which calendar year a given payment fell into. It aggregates twelve or thirteen pay runs into a single number. It generally excludes benefits in kind, which are reported separately. It does not identify a bonus, a share vest or a relocation payment as a distinct item, even though each one may need separate US treatment or separate sourcing. It shows National Insurance, which is a social security contribution dealt with under the US and UK totalisation agreement rather than a creditable foreign income tax. And it reports on a period that is nine months out of step with the US return it is being used for.

The practical instruction we give clients is simple. Send the P60 as a control total, and send every payslip for the same period as the working data. The P60 proves the payslips are complete. The payslips make the P60 usable.

P11D, P45 and the Benefits That Quietly Go Unreported

GOV.UK sets out at https://www.gov.uk/paye-forms-p45-p60-p11d that you receive a P45 if you stop working for an employer, a P60 if you are working for them at the end of the tax year, and a P11D if you get company benefits. Employers must report employee expenses and benefits to HMRC by 6 July following the end of the UK tax year.

The P11D matters more for high earners than most guides suggest. Private medical cover, a company car and fuel, interest free or low interest loans, professional subscriptions, club memberships, relocation support above the exempt limit and employer paid school fees all appear there. Under US rules these are compensation, and they belong in the US wage figure even though they never passed through the client's bank account. Two further wrinkles catch people out. Where an employer payrolls benefits rather than reporting them on a P11D, the value is already inside the P60 pay figure and must not be added twice. And where the employer operates a PAYE Settlement Agreement, the employer bears the UK tax on certain items, which changes what is creditable for the individual. Both facts have to come from the employer, not from the form.

A P45 is the leaving certificate. For US purposes it is most valuable as a boundary marker: it fixes the date employment ended, which anchors the sourcing of a final bonus, a payment in lieu of notice, or a share award that vests after departure. If a client changed employers mid year, we need both the P45 from the old employer and the P60 from the new one, because the new employer's P60 may include the old employer's figures and double counting is the obvious hazard.

SA302, the Tax Year Overview and the Self Assessment File

Where a client is inside UK Self Assessment, which almost every high net worth American in the UK is, the return itself becomes a primary source. The pack needs four things: the filed SA100 with its supplementary pages, the SA302 tax calculation, the tax year overview, and the HMRC statement of account.

The SA302 is HMRC's calculation of the tax due on the income declared. The tax year overview is HMRC's record of what was charged and what was paid. GOV.UK explains at https://www.gov.uk/sa302-tax-calculation that both are available for the last four years and cannot be accessed until 72 hours after the return was sent. That four year limit is the reason we ask clients to download and keep them every year rather than retrieving them when needed.

The supplementary pages are where the detail lives. SA105 gives UK property income. SA106 gives foreign income and any foreign tax credit relief claimed in the UK. SA108 gives capital gains. SA109 gives residence and remittance basis or split year positions. SA102 gives employment. Each maps to a different part of the US return, and the mapping is rarely one to one. UK relief for residential finance costs is given as a basic rate tax reduction rather than as a deduction, so the UK taxable property profit on SA105 cannot be carried straight to Schedule E. UK capital gains use different matching and pooling rules from US lot identification, so SA108 gains cannot be carried straight to Schedule D.

There is one further limitation nobody mentions. The SA302 produces a single total tax figure across all sources. Form 1116 requires foreign tax to be allocated between income categories, principally the general category for employment and the passive category for interest, dividends and most gains. The pack therefore has to contain enough source detail to allocate that single UK number across categories on a reasoned basis. A client who sends only the SA302 has given us the answer without the working.

How Do You Reconcile the UK Tax Year to the US Calendar Year?

This is the reconciliation every competitor mentions in one line and nobody explains. The standard advice is to use your monthly payslips. That advice is directionally right and mechanically incomplete, because UK payroll tax months do not run from the first of the month. They run from the 6th to the 5th. Month one is 6 April to 5 May, and month nine ends on 5 January. No year to date figure on any UK payslip lands on 31 December.

The correct allocator for an individual US taxpayer on the cash method is not the UK payroll period at all. It is the date the payment was actually or constructively received. Employment income belongs in the US calendar year in which it was received, and PAYE withheld on that payment is foreign tax paid in that same year. So the worksheet is not a table of UK payroll months. It is a list of payment dates. The two P60s then serve as control totals proving that no payment date was missed.

The reconciliation worksheet we use has one row per payment date and the following columns.

Payment date as shown on the payslip or bank credit, which determines the US calendar year
UK tax year the payment sits in, so the row can be tied back to the correct P60
Gross taxable pay for that payment, separating regular salary from bonus, commission, share plan proceeds and any one off award
PAYE income tax deducted on that payment, which is the creditable foreign tax for that US year
Employee National Insurance deducted, recorded but excluded from the foreign tax credit computation
Payrolled benefits included in that payment, flagged so they are not added again from the P11D
Employee pension contributions and employer pension contributions for that payment
The exchange rate applied and its source
The US dollar equivalent of gross pay and of PAYE

The evidence supporting the split is then straightforward to assemble and easy to defend: the twelve or thirteen payslips for each UK tax year, showing period, payment date and year to date figures; both P60s as control totals; bank statements showing the actual credits and their dates; and where an employer will provide one, a calendar year payroll summary produced directly from the payroll system. Where payslips genuinely cannot be recovered, a pro rata split of the P60 across the year is a fallback rather than a method, and the pack should contain a short written note recording the assumption, the basis used and why the primary evidence was unavailable.

A Worked Reconciliation for a London Based Managing Director

The following figures are purely illustrative and the exchange rate is an assumption, not a published rate. Assume a client paid monthly on the 25th, with a March bonus. Her UK 2024 to 2025 P60 shows total pay of 480,000 pounds. Adding up only the payments dated between 6 April 2024 and 31 December 2024 gives 247,500 pounds. The remaining 232,500 pounds was received on payment dates falling in January, February and March 2025, so it belongs in the US calendar year 2025, and that includes the March bonus.

Her UK 2025 to 2026 P60 shows total pay of 495,000 pounds. The payments dated between 6 April 2025 and 31 December 2025 total 258,750 pounds. Her US calendar year 2025 employment income is therefore 232,500 plus 258,750, or 491,250 pounds. At an assumed rate of 1.28 US dollars to the pound, that is 628,800 US dollars for Form 1040. The PAYE deducted on exactly the same set of payment dates is the withheld UK tax available for Form 1116 in that year. The two P60 totals, 480,000 and 495,000, are the control totals that prove nothing was dropped and nothing was counted twice.

The failure mode we see most often is a client who sends one P60 and assumes it covers the US year. It never does. It covers three months of one US year and nine months of another, and using it unadjusted overstates income in one year and understates it in the next, while putting the foreign tax credit in the wrong year entirely.

Foreign Tax Paid Versus Accrued and the Evidence Form 1116 Needs

This is where a UK information pack most often falls short, because the UK documents prove what was assessed and the US return needs to know what was paid. IRS Publication 514 at https://www.irs.gov/publications/p514 sets out the rule: a taxpayer using the cash method can claim the credit only in the year the foreign tax is paid. There is an election available on Form 1116 to claim credits on the accrual basis instead, but it cannot be made on an amended return, and once made it binds all later years. That is a decision to take deliberately, not by accident.

The consequence for a UK based American is significant and easily missed. PAYE deducted from salary is paid as it is withheld, so it lands in the US year of the payment. Self Assessment liabilities behave completely differently. GOV.UK confirms at https://www.gov.uk/self-assessment-tax-returns/deadlines that the online return and the balancing payment are due on 31 January following the end of the UK tax year, with payments on account due on 31 January and 31 July. So a balancing payment made in January 2026 relates to UK income from the year ended 5 April 2025, but for a cash basis US filer it is foreign tax paid in calendar year 2026. Any HMRC repayment works the same way in reverse and can trigger a foreign tax redetermination, so refunds have to be tracked, not ignored.

The foreign tax evidence file therefore needs to contain the following.

Payslips and P60s establishing PAYE withheld and the dates of the payments it was withheld from
The HMRC Self Assessment statement of account showing every charge, every payment, and the date of each
Bank statements or card receipts corroborating each payment to HMRC
Records of any HMRC repayment received, with the date, since a refund of foreign tax can require a redetermination
The SA302 for each relevant UK year, used to allocate total UK tax between the general and passive Form 1116 categories
Prior year Form 1116 carryover schedules, since excess credits carry back one year and forward ten years

Bank and Broker Statements: Building the FBAR Maximum Value File

The FBAR is a calendar year report, which makes it one of the few pieces of the pack that already lines up with the US year. The IRS confirms at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar that a report is required where the aggregate value of foreign financial accounts exceeded 10,000 US dollars at any time during the calendar year, that it is due 15 April with an automatic extension to 15 October requiring no request, and that it is filed electronically through FinCEN's BSA E-Filing System at https://bsaefiling.fincen.gov rather than with the tax return.

The word that governs the document request is aggregate. The threshold is tested across all accounts combined, so a client with fifteen accounts each holding a few thousand pounds is over it. And the reported figure for each account is the maximum value during the year, not the closing balance. FinCEN's guidance at https://www.fincen.gov/reporting-maximum-account-value permits reliance on periodic account statements issued at least quarterly where those statements fairly reflect the maximum value, and directs filers to convert the maximum value using the Treasury Bureau of the Fiscal Service exchange rate for the last day of the calendar year. That is a different rate rule from the one used on the income tax return, and mixing them up is a common error.

What we ask clients to obtain from each UK institution is specific.

The full legal name and address of the institution as it should be reported, not the trading brand on the app
The account number and account type for every account, including current, savings, offset, foreign currency and dormant accounts
Statements covering the whole calendar year, at minimum quarterly, or a written highest balance figure for the year
Confirmation of every account where the client has signature authority but no beneficial interest, including employer and company accounts
Joint account details including the other holder's name and address
Investment platform, stockbroker, spread betting and digital wallet accounts, which are financial accounts even though clients rarely think of them as bank accounts

Retention matters as much as collection. The IRS states that FBAR records covering the account holder name, account number, institution name and address, account type and maximum value must be kept for five years from the FBAR due date. In practice we ask clients to archive the underlying statements alongside the filed report, because the report itself does not evidence the number on it.

Form 8938 and the Wider Foreign Asset Picture

Form 8938 sits alongside the FBAR and asks a broader question. The IRS publishes the thresholds for taxpayers living abroad at https://www.irs.gov/businesses/corporations/do-i-need-to-file-form-8938-statement-of-specified-foreign-financial-assets and they are more than 200,000 US dollars on the last day of the tax year or more than 300,000 US dollars at any time during the year for an unmarried filer, and more than 400,000 US dollars or 600,000 US dollars respectively for a married couple filing jointly. Those thresholds sound generous until you price a UK investment portfolio and a directly held company stake at market value.

The key document difference is that Form 8938 reaches assets a bank will never send a statement for. The IRS confirms at https://www.irs.gov/businesses/corporations/basic-questions-and-answers-on-form-8938 that foreign stock or securities held outside a financial account must be reported. That means shares in a private UK company held on a paper certificate, an interest in a UK partnership or limited liability partnership, and loan notes issued by a foreign entity all need valuations and acquisition data that only the client can supply. For each such asset the pack needs the issuer's legal name and registered address, the acquisition date, the maximum value during the year, the year end value and the basis of the valuation.

UK Funds, OEICs and Investment Trusts: The PFIC Identification Pack

Non US pooled investment vehicles commonly meet the definition of a passive foreign investment company, and that includes many UK open ended investment companies, unit trusts, investment trusts and European domiciled exchange traded funds, including those held inside an ISA. Form 8621, described at https://www.irs.gov/forms-pubs/about-form-8621, is the information return for a shareholder of a passive foreign investment company or qualified electing fund. It covers the qualified electing fund election and the section 1296 mark to market election, and it carries an annual reporting requirement under section 1298(f).

A standard UK platform valuation is useless for this. It gives a total portfolio value and perhaps a gain figure computed on UK rules. What Form 8621 needs is holding level and lot level. In the returns we prepare, the PFIC pack is the single item that most often has to be requested three times.

The full legal name of each fund and its ISIN or SEDIN, since share classes of the same fund are separate holdings
Country of domicile of the fund, which is what determines whether it is foreign for US purposes
Every acquisition with date, number of units and cost, including automatically reinvested distributions, which each create a new lot
Every disposal with date, units, proceeds and the fund's own gain computation
All distributions received with dates, whether paid or accumulated within the fund
Year end unit holding and value for each share class
Whether the fund publishes a PFIC Annual Information Statement, which is the prerequisite for a qualified electing fund election
Whether each holding is regularly traded on a qualified exchange, which affects the availability of a mark to market election

The point most clients resist is that reinvested income inside an accumulating fund is an acquisition. A client with ten years of monthly accumulation units has hundreds of lots. That data exists in the platform's transaction history, and it has to be exported before anything else can proceed.

UK Company Shareholdings, Form 5471 and Related Reporting

For a business owner or an investor with private holdings, this is the heaviest part of the pack. Form 5471, described at https://www.irs.gov/forms-pubs/about-form-5471, is filed by certain US citizens and residents who are officers, directors or shareholders in certain foreign corporations under sections 6038 and 6046. Its schedules run to taxes paid or accrued, earnings and profits, transactions between the corporation and its shareholders, and stock acquisitions and dispositions. Which schedules apply depends on the filer category, which in turn depends on ownership percentage and on what happened during the year.

The UK evidence required is a specific list, and a set of UK statutory accounts on their own does not cover it.

The company's registered name, company number and registered office, and its Companies House filing history
The register of members and all share certificates, showing every class of share and every change during the year
Full statutory accounts, not filleted or abridged accounts, since a balance sheet and profit and loss account are needed
A trial balance or management accounts in the functional currency, because UK statutory formats do not present the analysis the schedules require
The corporation tax computation and CT600 for the accounting period, evidencing UK tax paid or accrued at the company level
Details of every transaction between the client and the company, including loans, director's accounts, dividends and management charges
Dates and terms of any acquisition, disposal, issue, buyback or reorganisation of shares during the year
Confirmation of the client's role as director or officer, and of any other US person holding shares

Where the UK accounting period does not match the calendar year, and it usually does not, the pack needs the accounts either side of the period so the US position can be built correctly. Dividends declared under UK company law also need the date of declaration and the date of payment separately, since only one of those matters for a cash basis individual.

Rental Agent Statements and UK Property Records

A letting agent's annual statement is a good starting point and a poor finishing point. It typically shows gross rent collected, agent commission, and repairs paid from rent. It does not show anything the US return needs beyond that. The purchase completion statement, the mortgage interest certificate, the schedule of capital improvements and the date the property was first available to let all have to come from the client.

Two structural differences drive the extra requests. First, US rules require depreciation on foreign residential rental property under the alternative depreciation system, which needs a cost basis, an allocation between land and building, and an in service date. None of those three appears anywhere in a UK document. Second, UK relief for residential finance costs is given as a basic rate tax reduction rather than as a deduction against profits, so the taxable profit figure on the SA105 pages is not the number that goes on Schedule E. The gross rents and the actual mortgage interest paid are what we need, not the UK net profit.

Exchange Rate Evidence: Which Rate, From Which Source

There is no official IRS exchange rate. The IRS states at https://www.irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates that it generally accepts any posted exchange rate that is used consistently, and directs taxpayers to use the rate prevailing when they receive, pay or accrue an item. The IRS also publishes a table of yearly average rates on that page, which is a legitimate and commonly used source for a steady stream of income such as monthly salary.

Three rules keep this clean in a real engagement. Use spot rates on the actual dates for discrete, material events such as a bonus, a share vest, a property sale, a large distribution or a Self Assessment payment. Use the IRS yearly average for regular recurring income where a daily rate adds precision without adding accuracy. And use the Treasury Bureau of the Fiscal Service rate for the last day of the calendar year for FBAR maximum values, because that is the specific rule FinCEN sets. Whatever you choose, apply it consistently across the return and record the source in the file. HMRC publishes its own monthly and average rates, and its own manual at https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim39505 notes that the London closing rate it publishes is not an official rate. HMRC rates belong in the UK return, not automatically in the US one.

What to Gather When the Documents Are Missing or the Years Are Old

Every checklist assumes a current year filer with a tidy folder. The clients who most need a document pack are the opposite: an American who has been in London for eleven years, who has changed employer three times, whose first bank has been absorbed into another, and who is now filing five years late. The pack for a catch up filing is built from institutional records rather than personal ones, and it is assembled in a particular order.

Start with the HMRC personal tax account, described at https://www.gov.uk/personal-tax-account. It shows income from work for the previous five years, how much income tax was paid over the last five years, the National Insurance record, the tax code, and the Unique Taxpayer Reference. For a client with no paperwork at all, that single login usually rebuilds the employment spine of five years of returns in an afternoon.

Then work outward through these sources.

Former employers: payroll departments can usually reissue a duplicate P60 or provide a statement of earnings, and a calendar year payroll extract is worth asking for at the same time
HMRC directly, where the employer no longer exists, since HMRC holds the payroll data employers submitted and can be asked for a record of pay and tax
SA302 tax calculations and tax year overviews for the last four UK tax years, retrieved from HMRC online services
The HMRC Self Assessment statement of account, which is the only clean record of when tax was actually paid and is essential for a cash basis foreign tax credit
Bank and platform archive requests in writing, asking for full statement history and a written maximum balance for each calendar year, which most institutions will produce for closed as well as open accounts
Share plan administrators, who hold vesting and exercise records that neither the employer nor the client usually retains
IRS transcripts, available through an Individual Online Account or by Form 4506-T as described at https://www.irs.gov/individuals/get-transcript, including wage and income transcripts, tax account transcripts and a verification of non-filing letter, which establishes what the IRS already holds
Prior US returns and any state returns, plus foreign tax credit carryover schedules, which determine what is still available to use

The order matters because the IRS transcript tells you what the IRS believes, the HMRC records tell you what happened, and the gap between the two is the work. Where a figure genuinely cannot be reconstructed, the answer is a documented, reasonable estimate with the basis recorded in the file, never a guess presented as a fact.

For a client entering the Streamlined Foreign Offshore Procedures, the volume of the pack is fixed by the programme itself. The IRS sets out at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states that eligible taxpayers file delinquent or amended returns for the most recent three years for which the due date has passed, delinquent FBARs for the most recent six years, and a Form 14653 certifying that the failure was non wilful, with the non residency test turning on being physically outside the United States for at least 330 full days with no United States abode. That means six calendar years of maximum account balances and three full years of income data, and it is why the archive requests go out on day one. Where a client's only failure is unfiled FBARs and the tax returns are correct and the tax is paid, late reports are submitted through FinCEN's BSA E-Filing System with a reason for late filing selected on the form. Our approach to catch up work is set out at https://us-uktax.com/streamlined-foreign-offshore-procedures.

The Delivery Order That Keeps a Cross-Border Engagement on Schedule

Because a UK P60 does not exist until after 5 April and employers have until 31 May to issue it, a US return for the previous calendar year cannot be finalised on UK employment data alone until well after the 15 April US deadline. That is not a problem, but it is a sequence. The automatic extension available to taxpayers living abroad, and a further extension where needed, exist precisely because foreign documents arrive late.

The order we work in is: first, the January to December payslips and bank statements, which allow the income and the FBAR to be built immediately; second, the platform and pension statements, which drive the PFIC and asset reporting; third, the P60 issued after 5 April, which confirms the control totals; fourth, the Self Assessment computation and statement of account, which finalise the foreign tax credit; and fifth, the company accounts, which usually arrive last. A client who sends the pack in that order is finished months ahead of one who waits to send everything at once.

Assembled properly, the UK information pack is not administrative overhead. It is the return. Every judgement in a cross-border filing, from which relief method to use, to which Form 1116 category a UK tax payment belongs in, to whether an accumulating fund is worth continuing to hold, is decided by the quality of the underlying documents. You can read more about how we handle US filings for UK based clients at https://us-uktax.com/us-tax-services and about the wider cross-border position at https://us-uktax.com/cross-border-tax-planning.