🇺🇸 United States vs 🇬🇧 United Kingdom

Tax residency, treaties and PE risk compared.

Dimension🇺🇸 United States🇬🇧 United Kingdom
Residency ruleCitizenship-based + Substantial PresenceStatutory Residence Test (SRT) — ties + days
Day threshold183 days183 days
Warning bandfrom 122dfrom 90d
Tax range10–37% federal + state20–45%
Tax treaties70+130+
PE riskHighMedium
Digital nomad visaNoNo
Best forUS citizens optimising via FEIE ($126,500) and treaty benefitsReturning expats using split-year treatment
Common pitfallUS citizens are taxed on worldwide income forever — there is no day-count exit.Even 16 days can trigger residency if you have 4+ ties to the UK.

Verdict

For most nomads optimising for residency safety, 🇬🇧 United Kingdom is the lower-risk base versus 🇺🇸 United States. United States's high PE risk and 183-day rule make it easier to trip into full residency.

Deep dive

🇺🇸 United States residency rules →

Deep dive

🇬🇧 United Kingdom residency rules →

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