96. FBAR, PFICs & Penalty Stacking: The Real Cost of Getting US Tax Wrong as a Brit

Most UK-US cross-border tax advisors fall into one of two camps: UK-based specialists who understand British and US tax intimately but charge eye-watering fees, or US-based CPAs who know their side of the Atlantic but have insufficient grasp of the UK side of things. This episode explores what happens when British expats end up in the wrong camp, and why finding someone who genuinely understands both systems, including the US UK tax treaty, while being based in America, has been so hard to come by. 

Richard Taylor, Chartered Financial Planner and founder of Plan First Wealth, is joined by Toni Sculthorpe, founder of Avante Tax and known online as "Your Tax Lady," to unpack the gap she's spent the last decade filling. After 25 years as a UK accountant, Toni was pulled into cross-border work when a client's US-based Amazon business exposed how badly disconnected American and British tax advice can be. As a British expat herself, now based in North Carolina, Toni frames the conversation through the lens of clients navigating dual tax UK and US obligations on both sides of the Atlantic. 

Richard and Toni walk through the most common, and most costly, mistakes British expats make once they've relocated: unreported FBAR accounts, ISAs that trigger PFIC penalties, mishandling a UK pension or US pensions during the transition, and the temptation to take tax advice from Facebook groups or ChatGPT instead of getting proper US tax help from a qualified professional. They break down why the IRS's reasonable cause can test hinges on whether you disclosed everything to your advisor, whether that advisor was actually qualified to advise on your situation, and whether you followed their advice, and why skipping professional guidance before a move can turn a $2,000-3,000 problem into a $30,000+ one. 

They also discuss why tax compliance and financial planning are too often handled in silos, with tax advisors and financial planners on opposite sides of the Atlantic never speaking to each other, and what it looks like when those two roles work in tandem instead of in isolation. 

Whether you're moving to America, already living there and unsure if you're fully compliant, or advising clients with assets on both sides of the Atlantic, this episode covers the spec