From 6 April 2025, the UK’s tax landscape for internationally mobile individuals changed significantly with the introduction of the Foreign Income and Gains (FIG) regime, replacing the long-standing ‘non-dom’ tax system after more than a century.

While much of the media focus has been on the departure of non-domiciles from the UK, the opportunities offered by the FIG regime, particularly for new arrivals and internationally mobile professionals, have gone largely unnoticed, as SRLV’s Senior Tax Manager, Tom Buchan, explains.

What Is the FIG Regime?

The FIG regime allows qualifying individuals to exclude offshore income and gains from UK taxation for a period of four tax years, while still retaining the ability to remit these funds to the UK without triggering a tax charge. This is a significant shift from the previous remittance basis rules and although some non-UK domiciles will lose out, new arrivals to the UK could stand to benefit.

A Strategic Opportunity for US Citizens and Green Card Holders

For US citizens and Green Card holders, who are subject to US Federal tax on their worldwide income regardless of residence, the FIG regime offers a window of opportunity.

In particular, individuals residing in high-tax US states, such as California, New York, and New Jersey, may find that the FIG regime helps minimise their overall state tax liabilities. By leveraging the UK’s new rules, US taxpayers could structure their affairs more efficiently during their first years of UK residency. Moreover, the four-year FIG window provides valuable time to fine-tune financial arrangements, allowing for a more considered long-term approach before transitioning to full UK tax residency.

Increased Reporting Requirements

One notable change under the FIG regime is the increased reporting burden. Unlike the previous rules for non-UK domiciles, the FIG regime requires all overseas income and gains to be reported on a UK tax return, even if they are excluded from UK tax.

For US taxpayers, many of whom already file complex annual US tax returns, this could seem daunting. However, with careful coordination between US and UK tax filings, the impact can be managed effectively.

How SRLV Can Help

At SRLV, we have extensive experience advising US citizens and Green Card holders on cross-border tax matters, including those who are:

• New to the UK and looking to make the most of the FIG regime
• Navigating the complexities of dual reporting
• Planning for life beyond the four-year FIG window

We work regularly alongside clients’ existing US tax and financial advisors to ensure a seamless and compliant approach to their international tax affairs. Whatever your situation, our team can help guide you through the transition to becoming a worldwide UK taxpayer and manage the annual interaction between US and UK tax systems.

For more information on any of the issues raised in this article, or for advice on international tax matters, please email tom.buchan@srlv.co.uk.

This material is published for the information of clients and contacts. It provides only an overview of the regulations in force at the date of publication, and no action should be taken without consulting the detailed legislation or seeking professional advice. Therefore, no responsibility for loss occasioned by any person acting or refraining from action as a result of the material can be accepted by the authors or SRLV LLP.