USA USA-UK tax agreement

Oct 1, 2020
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Hello Community,
I have a situation regarding a location / tax / green card for the United States that I’d like to get an expert opinion on.

I will try and outline the facts – and the possible scenarios, in the hope that you can get a better understanding of the situation

A guy is employed by a US subsidiary of an Italian company.
He is a full British citizen – with a UK passport – but since January 2015, he lived and worked in Boston, USA.
He arrived in Boston on an O1 Visa – but got a Green Card for himself and his family in 2017 – wife and two children (12 and 17).
He doesn't own a property or any assets in either the United States or the UK.
He is paying taxes in the United States – as has no income or earnings in the UK.

He will still officially live in the US until June 2021 – in Boston – but might begin to work some time from London – before his whole family moves to London in June 2021.
If he is on a US contract, I assume nothing changes regarding tax until next June – when he could switch to a UK contract, living and working in the UK.
At that point, as he would be leaving the US – completely – he would not have to pay tax in the USA.

So, is it correct what above or are there any issue coming from the different FY between USA and UK?

This guy will take a contract with the UK subsidiary of the same company group the American company belongs to.
He will be paid in the UK – and spend up to half his time there – with his family staying in the US until June 2021, as they have Green Cards.
The employee will retain his Green Card – as will still spend half my time in Boston – before he and his family move to the UK permanently in June 2021.
However, he will not be paid in the United States – and will not earn money in the US – He will also NOT transfer any money earned in the UK back to the USA.

I assume, being the employee a Green Card holder, he will still be liable for tax in the US – but also in the UK, as he will earn money there.
Am I wrong? I do not want he shall pay tax twice.
Is there any tax benefit stated by the tax treaty between the two countries which can save the employee's incomes?
I guess the main question is – is he better to stay on US contract until June 2021 – even if he spends a fair amount of time in London?

Hope this clear and would welcome your much appreciate comments.

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