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Jay Krause and Stuart Skeffington of Withers International LLP, and James Anderson of Skadden, Arps, Slate, Meagher & Flom LLP, examine the implications of changes to the domicile and residence rules for US citizens living in the UK after April 2008.

Proposed changes to the UK’s domicile and residence rules from 6 April 2008 hold a sting in the tail for US citizens who, unusually among foreign nationals residing in the UK, remain subject to their home system of taxation even while citizen in the UK – in their case, US federal income taxation on their global income.