THE ISSUES Migration
you have all the arts and the culture, and it’s English-speaking – that’s essential.’ Home Office figures show that more than
6,100 US citizens applied for UK citizenship in 2024 – a 26 per cent increase on 2023, and the highest number since records were first collected in 2004. Applications submitted in the last three months of the year were up 40 per cent compared to the same period in 2023. All the five immigration law experts Spear’s spoke to for this article predicted the jump in US applications for citizenship in 2025 would be higher still. The explosion in the number of Ameri- cans moving to the UK or exploring the op- tion of doing so is keeping London’s army of immigration lawyers, bankers, tax advisers and estate agents extremely busy. Kathryn Bradbury, partner and head of
citizenship and immigration at law firm Payne Hicks Beach, says she’s dealing with more enquiries from Americans than ever before in her 25-year career as an immigra- tion specialist. ‘There has been a very no- ticeable increase from the end of last year right through to now,’ she says. There’s little doubt about the reason: ‘Concerns about the Trump regime.’ Bradbury says there was also a bump aſter his first election victory in 2016, ‘but that was mostly enquiries – this is people actually moving here’.
T
he timing of presidential terms also fits in with the UK government’s new and ‘very generous’ Foreign Income
and Gains (FIG) Regime, brought in in April as a replacement for the scrapping of the non-dom status. At least 10 per cent of the UK’s 255,000 wealthy non-doms leſt last year aſter chancellor Rachel Reeves’ crackdown on the status, according to a report by for- mer Treasury economist Chris Walker. The true number could be even higher, accord- ing to a senior figure from a leading private bank, who tells Spear’s that 40 per cent of their UK-resident non-dom clients have leſt the country – and that the wealthier clients are, the more likely they are to leave. Among those who have leſt the UK are:
Egypt’s richest person and Aston Villa FC co-owner Nassef Sawiris; Shravin Bharti Mittal, an heir to billionaire Indian industri- alist Sunil Bharti Mittal; and South African Richard Gnodde, Goldman Sachs’ most sen- ior banker outside the US. The non-dom scheme had allowed (most- ly) foreign people living in the UK to pay tax
only on income and capital gains arising in the country, but not on those generated overseas. (Most ordinary people living and working in the UK pay tax on income and capital gains arising here and abroad.) The heirs of non-doms were previously able to avoid paying the UK’s 40 per cent inher- itance tax on assets above £325,000. But that is no longer the case. With so many wealthy non-doms fleeing
the UK, it seems odd that many rich Ameri- cans are choosing to move in. I asked Mi- chael Lewis, a partner at EY and its special- ist at US/UK cross border tax services, to explain why. ‘The key thing is that Ameri- cans pay tax on their worldwide income,’ he says. Non-American non-doms leaving the UK are tempted by low or zero taxes offered by places like Switzerland, Monaco or Dubai, or the annual ‘flat tax’ of €200,000 in Italy. Those schemes, says Lewis, ‘don’t work for Americans, as they can never go below the base rate. Italy isn’t more attractive as they’ll have to top up the tax [they pay] to the US base rate.’ Italy, he says, is also not as well set up to
support rich foreign people to settle in. ‘If you come to the UK there is a support sys- tem of maybe 400,000 people dedicated to advising on tax, on houses, on property, on schools,’ he says. ‘You can come to the UK and be very well looked aſter if you’re wealthy. It’s not necessarily the same if you turn up in Italy.’ The fear of the UK’s much higher than av-
erage inheritance tax is also ‘cushioned’ for Americans thanks to a ‘very generous’ UK- US estate tax treaty. It means Americans are protected from the UK’s 10-yearly charging regime, which makes overseas people who have been UK tax resident for 10 of the past 20 years in scope for global UK inheritance tax. This applies even if the person leaves the UK before their death, as a ‘tail’ period remains that exposes their global estate to UK inheritance tax if they die within 3-10 years of leaving the UK. Lewis says tax is oſten the primary reason
rich Americans are seeking out a move to the UK, but ‘culture, schools, the legal sys- tem and the language are also key’. ‘The UK is the easiest move culturally, and the UK is seen as stable and secure for their assets,’ he says. ‘Trump is oſten the lit- tle extra push that gets people who were considering [leaving the US] to get across the line and do it.’
THEY DON’T
REALLY WANT TO GO TO FLORIDA.
THEY’LL SAY THERE ARE TOO MANY MOSQUITOES, OR ‘THEY DON’T HAVE PEOPLE LIKE ME’
Some New Yorkers, he says, had thought
about moving to Florida, where there is no state income tax compared to New York’s state tax, which is as high as 10.9 per cent for those earning more than $25 million. ‘But they don’t really want to go to Florida. They’ll say there are too many mosquitoes, or “they don’t have people like me in Flori- da. So why not do 10 years in London, where there is a whole community of people who are similar to me.”’ It is primarily London that is attracting
the influx, but some are venturing to the Cotswolds, the West Country and Edin- burgh. American comedian Ellen DeGe- neres and her American-Australian actor wife Portia de Rossi moved from Montecito, California to a £15 million farmhouse in the Cotswolds last year, with DeGeneres report- edly saying Trump’s election made her want to ‘get the hell out’. An (as yet unknown) American bought
The Holme, a vast 40-bedroom mansion within the grounds of Regent’s Park, for £138.9 million in January, making it the sec- ond most expensive house ever sold in the UK. The Land Registry records The Holme’s official buyer as a UK subsidiary of Zedra, a
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