Tax on Deferred overseas Income

[EHM]

I'm a UK national who returned to the UK in 2024 after living/working in USA for 25 years. I worked for a US company, 100% in the US, and retired from there in 2022. However, this year I will receive some deferred compensation (cash and shares) that will taxed as employment income by my former employer in the US. It can all sit in the US while I figure out what to do with it but eventually I'll want to bring it to the UK since this is where I live now. My questions:

- since this deferred comp relates to work done prior to April 2025 does it get taxed under the new FIG regime or the pre-2025 remittance rules?
- under either regime, would I have any UK tax liability at all since the compensation was earned overseas when I wasn't resident in the UK?

Thanks

[darthblingbling]

The tax point for employment earnings is the earlier of when you received it or when you are legally entitled to it, you can't just opt to receive later to shift the tax point (should flag that directors have stricter rules on timings).

Shares are a bit different and you would need to look carefully at the share plan and it's hard to give general advice.

However the sourcing of the income (and shares when considering a vesting period) may relate to periods you were non resident and had no UK workdays so could be wholly or partly exempt from UK tax (but still taxable in the US). This is regardless of the FIG regime.

[EHM]

Thanks, the deferment was part of the compensation plans run by my employer (categorized as non-qualified plans under US code), I made pre-tax contributions direct through payroll and there was some employer match over the period. Each time I signed up I had to nominate when the plans would pay, no changes allowed. I'll try to track down the old plan rules and read up on what HMRC says about income sources. Appreciate your feedback, thank you.