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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: United States of America: Residence

The United States taxes its citizens on their world-wide income wherever they may be resident. United States citizens are not, however, necessarily ‘residents of the United States’ for the purposes of the agreement.

Nevertheless, where an individual claims relief from United Kingdom tax on income arising in the United Kingdom on the grounds that he is a resident of the United States for the purposes of the agreement, the approach to be adopted in considering the claim will depend upon whether or not the individual concerned is a United States citizen.