Comprar imóvel em Reino Unido sendo cidadão americano

Stamp Duty Land Tax (England and Northern Ireland) layers surcharges. A 2% non-resident surcharge applies if you spent fewer than 183 days in the UK in the relevant 12 months — which most US buyers will trigger. On top, since 31 October 2024 a 5% additional-dwelling surcharge applies if you already own any property anywhere in the world. For a US buyer purchasing a second home, both stack: roughly 7 percentage points above the standard residential rates on every band. Model the full SDLT before you offer — it is often the largest single cost.

Most London flats are leasehold, not freehold: you own the right to occupy for a term, paying ground rent and service charges, with the freehold held by someone else. Short leases (under ~80 years) are expensive to extend and hard to mortgage. Houses are more often freehold. American buyers used to outright ownership routinely underestimate this — always check the remaining lease term, ground-rent escalation and service-charge history before committing.

UK banks and specialist lenders do mortgage non-resident and US buyers, typically at 65-75% loan-to-value in sterling, but some mainstream lenders decline US persons because of FATCA reporting burdens. Expect more paperwork, and budget for GBP/USD exchange risk on both the purchase transfer and the life of any sterling mortgage. Buying through a US-based lender is generally not possible for UK property.

Buying through a company is usually a trap for residential property. A foreign company buying a UK dwelling over £500,000 pays a 17% flat SDLT rate, and company-held homes over £500,000 face the Annual Tax on Enveloped Dwellings (ATED) — a recurring charge running into tens of thousands of pounds. For almost all individual US buyers, personal ownership is simpler and cheaper; take advice before any corporate or trust structure.

The US taxes its citizens on worldwide income wherever they live. UK rental income goes on your US return (Schedule E) as well as to HMRC, with foreign-tax-credit relief under the US-UK treaty. A sterling mortgage can create a taxable foreign-currency gain under IRC §988 when you repay or refinance, even if the property value did not rise in dollars. UK bank and mortgage accounts trigger FBAR and FATCA (Form 8938) reporting. And holding UK property via offshore funds can create punitive PFIC exposure — avoid fund wrappers.

UK property is UK-situs, so it is exposed to UK inheritance tax (40% above the nil-rate band) — and as a US citizen you also face US estate tax on worldwide assets. The US-UK estate and gift tax treaty coordinates the two and provides relief, but the interaction is complex and worth planning before purchase, especially for higher-value homes. Coordinate UK and US advisers rather than relying on either alone.