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Posted Fri, 03 May 2024 00:32:01 GMT by Sean
Hi, I have 2 parts to my questions: I was based in the US for several years and have half of my employer awarded stock appreciation rights (SARs) vested while there. Now I am U.K. resident, please advise where I will be taxed when I exercise them (I believe it is taxed at source ie paid to the IRS)? Also for my remaining stocks which have not yet vested, where will these be taxed, as I believe they will be paid to me in the U.K. when exercised.
Posted Mon, 13 May 2024 08:34:41 GMT by HMRC Admin 32 Response
Hi,

You will be taxed in the UK.

Thank you.
Posted Mon, 13 May 2024 08:58:13 GMT by Sean
Hi, a spoke to my US accountant who advised all income originating in the US will be taxed in the US. This includes income from rental properties, bank savings interests, stock options awarded as part of work conducted in the US as well as private pension schemes. I think this is also in the tax treaty. While I was in the US I paid tax on my UK rental income and savings in the U.K. so makes sense same applies the other way.
Posted Thu, 16 May 2024 09:10:37 GMT by HMRC Admin 25
Hi Sean,
If  you are a UK resident and domicile at the time of vesting, you are liable on your worldwide income so you would be taxed in the UK.
If  you are also taxed in US, you can then claim Foreign Tax Credit Relief.
Please see guidance here:
Tax on foreign income
Thank you. 

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