Report of Foreign Bank Accounts
FinCEN Form 114. Required of any US person with aggregate foreign financial accounts above USD 10,000 at any point in the year. Penalties for non-filing are severe — up to USD 10,000 non-wilful, far higher wilful.
US citizens and green card holders stay in the US tax net wherever they live. Many UAE tax structures that work perfectly for everyone else — a UAE Free Zone company, an offshore investment vehicle, a non-US mutual fund — create disastrous US tax consequences. We handle the UAE side with full awareness of the US pitfalls, in coordination with your US tax specialist.
US-Connected Individuals in the UAE at The Tax Lead. We advise US citizens, green card holders and US dual-nationals living in the UAE on the UAE tax position (no personal income tax, but CT applies above the AED 1m business revenue threshold for sole traders), US tax compliance via trusted US co-counsel, FEIE / FTC optimisation, FBAR / Form 8938 reporting, PFIC traps on UAE investment funds, and estate planning across both regimes.
Americans abroad face a different set of tax obligations from everyone else. These are the six that most often blow up UAE structuring plans — and that we design around from the start.
FinCEN Form 114. Required of any US person with aggregate foreign financial accounts above USD 10,000 at any point in the year. Penalties for non-filing are severe — up to USD 10,000 non-wilful, far higher wilful.
Foreign Account Tax Compliance Act. Form 8938 attached to the US 1040 reports specified foreign financial assets above thresholds (USD 50k single resident, USD 200k single abroad, higher for MFJ). Separate from FBAR, overlapping scope.
Non-US mutual funds, ETFs and many pooled investment vehicles are PFICs. US tax treatment is punitive (excess-distribution regime, no capital-gain rates). Common trap when a US-connected person buys Dubai or London-domiciled funds.
US person owning 10%+ of a foreign corporation (CFC) is subject to GILTI — current-year inclusion of foreign earnings even without distribution. A UAE Free Zone company owned by a US citizen often triggers GILTI from day one.
Credit against US tax for foreign taxes paid. UAE has no personal tax so FTC gives little relief — different from, say, UK where UK tax paid can offset US tax. Means UAE residence doesn’t automatically reduce your US tax bill.
Section 911 exclusion of earned income up to annual limit (~USD 130k+ indexed) for qualifying US persons abroad — via physical presence (330 days) or bona-fide-residence test. Only covers earned income, not investment income or distributions.
The classic US expat position — US passport, UAE residency, worldwide income still US-taxable.
Same US tax exposure as citizens, plus the ongoing question of whether to maintain the green card.
Mixed-nationality households, people planning to go to the US on L-1/H-1B, and former L-1/H-1B holders returning to UAE.
We’re not US CPAs or Enrolled Agents. We don’t prepare US returns. We’re honest about that from the first conversation. What we do is UAE structuring that doesn’t accidentally hand you a GILTI inclusion or a PFIC time-bomb — which is where most other UAE firms slip up.
Most UAE firms will happily set you up with a Free Zone company and recommend a Dubai-listed fund — both potentially disastrous for a US-connected client (GILTI inclusion on the company; PFIC excess-distribution regime on the fund). We flag these before they happen.
We work with US CPAs and Enrolled Agents who specialise in Americans abroad. Where your return prep needs to happen in competent US-focused hands, we make the introduction and coordinate the engagement.
The UAE and the US do not have a comprehensive tax treaty. No treaty tie-breaker, no FTC relief from UAE (because UAE has no personal tax), limited totalisation agreement scope. The planning carries the weight that treaty relief would otherwise bear.
UAE-side engagement — residence, entity, CT/VAT compliance — on fixed fees. The US side is handled by whichever US adviser you choose, on their fees. You see both numbers up front, nothing hidden.
Many US-connected clients also have UK connections (previously UK-resident, UK property, UK family). Our sister UK practice covers that side under the same engagement. US specialist handles the US side — three-country coordination from a single UK/UAE point of contact.
Where you’re US-connected AND UK-connected. Phase 1 planning memo covering UK side; US CPA covers US side; we coordinate.
Entity choice with GILTI / CFC analysis built in — before you incorporate, not after.
UAE QFZP position with full awareness that the US tax position may make 0% UAE irrelevant for the shareholder.
Annual UAE CT return for the UAE entity, with records supporting Form 5471 that your US adviser needs.
Books kept to support both UAE compliance and US foreign-entity disclosure forms.
For families or small groups where UAE + UK + US all need coordinated handling — fractional senior leadership.
Book a free 20-minute Discovery Call. We’ll scope your position, agree the right engagement shape, make US-specialist introductions where needed, and send you a written fixed-fee quote within two business days.