Living, working or building wealth internationally can create tax consequences in more than one country — often at the same time.
Bates Baker advises US and UK connected individuals on how the two tax systems interact, with a particular focus on planning around major life, investment and business events.
Bates Baker was founded by Sally Hawkins, a US Certified Public Accountant with more than 15 years of Big Four experience advising multinational businesses, founders and internationally mobile individuals — across international tax, financial services, fintech and digital assets.
US and UK tax residence
Pre-arrival and departure planning
Timing of income, gains and transactions
Foreign tax credits and double taxation
US state tax residency
UK Foreign Income and Gains (FIG) regime
Long-term residency and exit considerations
An investment that is tax-efficient in one country can be highly inefficient in the other. This is particularly important for US-connected individuals in the UK, where investment funds, ISAs and other common UK investments can create unexpected US tax and reporting consequences.
Planning can help identify problematic investments, structure assets more efficiently across both systems and coordinate the use of foreign tax credits and available reliefs.
PFIC and CFC considerations
Family Limited Partnerships and Family Investment Companies
US and UK investment accounts
ISAs and US tax considerations
Foreign tax credit planning
Capital gains
Cross-border real estate investments
Cross-border investment structures
US and UK retirement systems were designed around very different tax rules. When retirement accounts cross borders, questions can arise around contributions, growth, distributions, transfers and when each country has the right to tax the income.
Planning can help preserve the intended tax benefits of retirement savings, identify opportunities before and after a move, and avoid transactions that may have unexpected consequences in the other country.
IRAs and Roth IRAs
401(k)s and other US retirement plans
UK pensions and SIPPs
Roth conversions
Pension contributions and distributions
US/UK treaty considerations
Cross-border retirement planning
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Strategic US and UK cross-border tax advice for individuals, founders, families and expanding businesses navigating both tax systems.