The UK’s old non-dom tax regime ended on 6 April 2025, replacing the remittance basis with a residence-based system that can bring more foreign income and gains into the UK tax net.
For Americans living in the UK, that is more than a technical rewrite. Someone who once kept US investment income offshore and relied on the remittance basis may now face a very different calculation. At the same time, US citizens generally remain subject to US tax rules on worldwide income wherever they live.
What Exactly Ended With the Non-Dom Regime?
From 6 April 2025, the remittance basis can no longer be used for current foreign income and gains. Previously, qualifying UK residents who were non-UK domiciled could use the remittance basis so that certain foreign income and gains were generally taxed in the UK only when brought, or “remitted,” there.
That framework has gone. UK residents are now generally taxed on worldwide income and gains as they arise, unless they qualify for a specific relief. HMRC also confirms that domicile has been replaced by tax residence as the relevant connecting factor for these rules.
What Replaced the Remittance Basis?
The main replacement is the four-year Foreign Income and Gains, or FIG, regime.
A qualifying resident can claim relief on eligible foreign income and gains during their first four years of UK tax residence, provided that residence follows at least 10 consecutive tax years of non-UK residence.
| Old system | New system from 6 April 2025 |
| Based heavily on domicile | Based on tax residence |
| Remittance basis potentially available | Remittance basis abolished |
| Offshore income could receive remittance treatment | FIG relief available only to qualifying new residents |
| Long-term access possible in some cases | FIG window limited to first four residence years |
The four-year limit is where things get particularly relevant for people who were already living in Britain.
What If You Have Already Lived in the UK for Several Years?
Existing residents do not automatically receive four fresh years of FIG relief from April 2025. The clock looks back to when the person first became a UK tax resident following the required 10-year period of non-residence.
Imagine an American who moved to Manchester and became UK resident in the 2022/23 tax year after spending their entire previous life in the US. The 2025/26 tax year would already be their fourth year of UK residence. They may therefore have only that year remaining within the FIG window, rather than another four years starting in 2025.
Someone resident for longer may have no FIG eligibility at all.
What Happens to US Income and Investments Now?
For people outside the FIG regime, keeping money in America does not recreate the old remittance-basis protection. US bank interest, dividends, rental income and gains on US investments may now fall within UK taxation as they arise.
The US side continues as well. US citizens abroad generally report worldwide income on their federal returns, including income earned or received outside the United States.
So, perhaps awkwardly, a US brokerage account that once remained mostly a US tax issue can now require closer coordination between both systems. Foreign tax credits and the US-UK treaty may help with double taxation, but the outcome depends on the income involved.
What About Income Left Offshore Under the Old Rules?
Historic offshore income has not simply been forgotten.
Foreign income and gains generated before 6 April 2025 under the old remittance basis can still become taxable when remitted to the UK. However, former remittance-basis users may be able to use the Temporary Repatriation Facility, or TRF.
Under the TRF, qualifying amounts can be designated at:
- 12% for 2025/26
- 12% for 2026/27
- 15% for 2027/28
Once properly designated, those amounts can generally be remitted without another UK tax charge on the remittance.
For someone with years of offshore savings, that transition rule may be more immediately useful than FIG itself.
What Changed for UK Inheritance Tax?
The reforms go beyond income and capital gains.
From 6 April 2025, UK Inheritance Tax moved from a domicile-based framework to one focused on long-term UK residence. Broadly, someone can become a long-term UK resident after being UK resident for at least 10 of the previous 20 tax years. Their overseas assets may then fall within UK Inheritance Tax.
That makes residence history increasingly important for Americans holding US property, investments, trusts or other assets.
The non-dom era, then, has not merely been renamed. For long-term Americans in Britain, the practical questions have shifted: how long have you been resident, does FIG still apply, what old offshore income remains, and are your US assets now exposed differently under UK rules? Those are the numbers worth reviewing first.