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bigduckontax, Accountant
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I am a citizen of Ireland (dual USA) but my husband is only

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I am a citizen of Ireland (dual USA) but my husband is only USA. According to the Common Area Travel Agreement between UK and Ireland, Irish citizens can live in UK, work, buy property, earn pensions....and it is reciprocal in Ireland with UK citizens, despite Brexit. We are hoping to immigrate to the UK but need to know the tax obligations we would have there. We are retired seniors, all income is from US pensions and investments. Can you find an expert in this particular field if inquiry?
JA: Have you talked to a tax professional about this?
Customer: no
JA: Anything else you want the Accountant to know before I connect you?
Customer: that is our issue in a nutshell

Hello, I am one of the experts on Just Answer and pleased to be able to help you with your question.


If you are resident in the UK you will be liable to UK taxation on your world wide income. You will have to rely on the Double Taxation Treaty between the UK and the States, which precludes the same income stream being taxed in both jurisdictions, for protection.


This is achieved my means of tax credits, the tax paid in the States being allowed as a tax credit against your UK liability.

bigduckontax and other Tax Specialists are ready to help you
Customer: replied 16 days ago.
Ok, I'm going to assume that tax rates in the UK are higher than US although we pay both US federal and State of California. So let's say our total income from pensions and interest, jointly is about $200,000 year and we pay tax of about 45%. If UK tax, both for UK and more local, is, say, 56%, then we would pay 11% to UK. ?
Customer: replied 16 days ago.
I prefer email...….but if you insist I can phone you tomorrow, Friday.....

The UK has Double Taxation Teaties with a number of individual US States also and California is one of those. The same tax credit system applies.r


I do not insist on a telephone call. Thank your for your support.