Why this mattersThe IRS and HMRC can both think you're resident. The treaty decides who wins.
Cross-border life regularly produces years where two countries each have a strong claim on you for tax. The substantial presence test, closer-connection exception, UK statutory residence test, and the US-UK treaty tie-breaker rules all interact — and the answer matters for everything from where your salary is taxed to whether your ISA gains are reportable. Getting the residency call wrong in year one cascades through every return for as long as your situation lasts.
- →Substantial-presence calculations using the IRS day-count rules
- →Closer-connection exception (Form 8840) when day-count breaks against you
- →UK statutory residence test reconciled with US position
- →Treaty tie-breaker analysis on Form 8833 for the years it matters