Introduction: The HMRC Wealthy Team Has Your Name. Now What?
The HMRC Wealthy Team published a multi-year plan on 28 October 2026. It sets out how HMRC will find, sort and examine Britain's 1.3 million wealthy taxpayers. A few weeks earlier, it had written to a few hundred of them. Each letter invited the recipient to a meeting about assets, investments and overseas arrangements. If you are an American working in London, you probably sit inside that population. A single year of income above £200,000 is enough to qualify.
Most of the coverage so far treats the plan as a story about British billionaires. However, the plan reads differently for a US citizen with a New York brokerage account, a Boston rental flat and a London salary. Your affairs span two tax systems. HMRC now says outright that it will connect data across borders, recruit offshore specialists and test penalty decisions harder. At TaxYork, we prepare US and UK returns for exactly this kind of household, so this guide explains what the plan changes. It also shows how the HMRC Wealthy Team sees American assets and what to reconcile before you reply.
What the HMRC Wealthy Team Actually Is
The HMRC Wealthy Team is the part of HMRC's Wealthy and Mid-sized Business Compliance directorate that manages individuals with high income or substantial assets. It replaced the old High Net Worth Unit and Affluent Unit, which HMRC merged in 2017. Furthermore, it does not deal only with people under enquiry. It reviews the whole population each year. It also allocates dedicated case workers to complex customers and coordinates specialists across taxes.
HMRC publishes a contact page for the Wealthy Team, which invites you to write if you think you belong with it. That includes people who do not know their compliance manager. That detail tells you something important. Membership is not a status you apply for. Instead, HMRC assigns it from data, and many people inside the population never receive a letter.
Why This Matters More to Americans
Americans in Britain carry a structural risk that British-born clients do not. Specifically, the US taxes you on citizenship, so you file a Form 1040 every year regardless of where you live. Many clients therefore assume their US return settles their US income. It does not. As a UK resident, you must also report US dividends, gains and rental profit on your Self Assessment return. You then claim relief for US tax under the treaty.
As a result, the most common error we find is not hidden money. Rather, it is US income that the IRS knows about in full and HMRC has never seen. The new plan is designed to surface precisely that kind of gap.
What the HMRC Wealthy Team's 2026 Compliance Plan Changes
The plan, titled Modernising HMRC's approach to wealthy compliance, followed criticism from the National Audit Office report on collecting the right tax from wealthy individuals. Parliament's Public Accounts Committee added its own. It groups HMRC's commitments into seven themes. For a cross-border household, three of them matter far more than the rest.
The Numbers HMRC Published
HMRC defines wealthy individuals as those with income over £200,000 or assets over £2 million in any of the last three years. That population grew from around 700,000 in 2021 to 2022 to 1.3 million in 2025 to 2026. The criteria did not change. Together, these individuals paid £160 billion in tax in 2025 to 2026. Meanwhile, HMRC puts the wealthy tax gap for 2024 to 2025 at £3.6 billion. That is 6% of the total gap in its Measuring tax gaps series.
Enforcement figures are rising too. Notably, the number of penalties charged to wealthy individuals rose from 456 in 2023 to 2024 to 803 in 2025 to 2026. That is a 76% increase in two years, and it predates most of the new capability the plan describes.
Seven Themes, Three That Bite
The first theme that matters is data. HMRC commits to connecting customer, ownership and third-party data and to using automated triggers and artificial intelligence to spot risks earlier. The second is people. HMRC aims to add 400 specialists focused on offshore non-compliance by the wealthy by 2030, and it has already recruited 244. The third is penalties. In April 2026, HMRC introduced a mandatory referral process for complex penalty cases and set up a specialist penalty network.
Consequently, the HMRC Wealthy Team is moving away from generalist inspectors who accept a modest careless penalty untested. Penalty decisions in complex wealthy cases now pass through specialists before they reach you.
The Timeline Through 2030
The plan attaches dates to its data ambitions. From 2027, HMRC will use Cryptoasset Reporting Framework data and enhanced Common Reporting Standard data. From April 2028, it will use improved bank and card data to pre-populate digital services and prompt people to register for Self Assessment. We covered that change in our guide to HMRC third-party data from 2028. From 2030, the UK will join the OECD framework for automatic exchange of real estate information. In addition, HMRC will publish a standalone offshore tax gap estimate in 2027.
Each of these dates closes a window. Therefore, an error that looks invisible in 2026 will be far easier for the HMRC Wealthy Team to find by 2028.
Are You on the HMRC Wealthy Team's List?
Most American professionals in London do not think of themselves as wealthy in the HMRC Wealthy Team's sense. Nevertheless, the thresholds are low relative to City pay, and the three-year look-back keeps you inside long after a single strong year.
The £200,000 and £2 Million Tests
The income test uses any one of the last three years. So a managing director who earned £260,000 in 2023 to 2024 stays in the population until 2026 to 2027. A move to a lower-paid role does not change that. Similarly, a founder who sold a company once can sit inside the asset test for years. The HMRC Wealthy Team uses these thresholds to find people with complex affairs. However, HMRC states clearly that they do not tell the whole story.
Importantly, HMRC admits it does not know anyone's total wealth, because individuals are not required to report it. It is therefore working with academics to improve its wealth estimates. In practice, the HMRC Wealthy Team builds the picture from fragments: PAYE records, Land Registry entries, Companies House filings, exchanged account data and open-source information.
How US Assets Get You Counted
Your US balance sheet counts towards the £2 million asset test in principle. That holds even when the HMRC Wealthy Team cannot yet value it precisely. A Manhattan apartment, a 401(k) and a taxable brokerage account all form part of your wealth. For example, a US citizen with £700,000 of UK property equity and $2 million in US investments clears the asset threshold comfortably.
Exchange rates add a quirk. The thresholds are in sterling. Consequently, a weaker pound pushes Americans with dollar assets further inside the population. Accordingly, you should assume membership if your combined net worth sits anywhere near £2 million.
What the HMRC Wealthy Team Can and Cannot See From America
HMRC receives information from more than 100 jurisdictions on about 12 million offshore accounts each year under the Common Reporting Standard. The United States, however, does not participate in that standard. Instead, the UK and US exchange data under the reciprocal FATCA agreement described on the US Treasury FATCA page. The flow from America is narrower than the flow from Europe. It centres on items such as deposit interest and certain US-source income.
Narrower does not mean blind. HMRC can also request specific information from the IRS under Article 27 of the US-UK treaty. You can read it on the IRS UK tax treaty documents page. Moreover, the HMRC Wealthy Team can simply ask you. As we explain below, that is exactly what the recent letters do.
Inside the HMRC Wealthy Team: Managers, CCTO and High Risk Wealth
The plan describes three escalating layers of attention inside the HMRC Wealthy Team. Understanding where you might fall tells you how much preparation a reply deserves.
The Customer Compliance Manager Model
Around 8,000 wealthy customers are reviewed by Customer Compliance Managers each year to decide what level of engagement they need. Of these, around 2,400 are allocated a dedicated manager, supported by about 100 permanent managers and a wider network of specialists. In addition, HMRC identified more than 200 billionaires with a UK tax footprint in summer 2026 and allocated a manager to every one of them.
A Customer Compliance Manager is your single point of contact with the HMRC Wealthy Team. They build a joined-up view of you and your connected interests, then coordinate other HMRC teams. That sounds benign, and often it is. However, the same manager sits at the centre of HMRC's risk assessment. Where deliberate behaviour appears, they support the use of its full civil and criminal powers.
The Complex Cross-Tax and Offshore Team
HMRC set up the Complex Cross-Tax and Offshore team in April 2025. It brings together more than 100 specialists from different tax regimes. They work alongside external recruits with wealth planning and family office experience. Its purpose is to handle cases where risk crosses personal and business taxes, multiple entities or offshore arrangements.
For an American owner of a UK company with a US holding structure, that description fits closely. Consequently, an HMRC Wealthy Team case that once went to one inspector may now draw corporate, international and personal tax specialists together.
The High Risk Wealth Programme
The High Risk Wealth Programme began in 2018 for the most complex and highest-risk cases. It involves senior-level discussions, specialists from across HMRC and, where needed, external counsel. Decisions follow HMRC's Litigation and Settlement Strategy.
Few Americans in Britain will ever move beyond the ordinary HMRC Wealthy Team caseload into this layer. Still, it matters. The plan says the programme now targets those who design or facilitate non-compliance, not only the taxpayers. Alongside it, HMRC's sanctionable conduct powers for tax advisers took effect from 1 April 2026, and mandatory agent registration began on 18 May 2026.
The HMRC Wealthy Team Invitation Letter: Voluntary, Not Harmless
Press reports in October 2026 described letters from the HMRC Wealthy Team inviting recipients to meet their Customer Compliance Manager. HMRC said the number sent was in the low hundreds and that compliance managers are not new. The letters, however, arrived weeks before the plan was published, and they show the plan's approach in action.
What the Letters Ask
Reportedly, each letter invites a discussion of sources of wealth, investments, companies, partnerships and family office arrangements. The suggested agenda also asks about tax advice taken in the past year. HMRC frames the meeting as a way to resolve uncertainty early. It adds that talking now may avoid a formal compliance check later.
For an American, every item on the HMRC Wealthy Team agenda has a US twin. Your Form 1040, your FBAR and your Form 8938 already describe your accounts and income to the IRS. Therefore, whatever you say to HMRC becomes a second account of the same facts, and the two must match.
Why the Missing Safeguards Matter
The letters are invitations, not formal information notices. A notice under Schedule 36 to the Finance Act 2008 must be reasonably required to check your tax position. You can usually appeal a taxpayer notice within 30 days. A voluntary meeting carries none of those limits. Accordingly, the HMRC Wealthy Team can record and use anything you volunteer. It does not matter whether HMRC could have demanded it. Our guide to Schedule 36 information notices covers the formal route in detail.
Privilege adds a further trap. Following the Supreme Court's decision in Prudential, legal advice privilege in Britain protects advice from lawyers only. Tax advice from accountants is disclosable. Similarly, the US practitioner privilege under section 7525 is a US rule and gives no protection against HMRC.
The Prompted Disclosure Question
Timing changes your penalty. Under Schedule 24 to the Finance Act 2007, a careless inaccuracy costs 0% to 30% when you disclose unprompted. A prompted disclosure costs 15% to 30%. A disclosure counts as unprompted only if you make it before you suspect HMRC has found, or is about to find, the error.
The HMRC Wealthy Team may argue that a personal letter about your assets makes any later disclosure prompted. In our experience, the prudent course is to assume it will. As a result, the most valuable work happens before a letter arrives, not after.
Where Americans' UK Returns Usually Break
We see the same three omissions when we review the UK returns of US citizens. Each one is easy for the HMRC Wealthy Team to spot once it holds your US data, and each one has a different treaty outcome.
US Brokerage Income on the UK Return
US dividends and interest are taxable in Britain once you are UK resident and taxed on the arising basis. Many clients left them off because a US broker issued a 1099 and the US return took care of it. However, the treaty treats US citizens differently from other UK residents. Under Article 24, the UK gives credit only for the US tax the US could charge a non-citizen UK resident, which is 15% on dividends. HMRC therefore collects the balance. The US then re-sources the income so you can claim that UK tax as a credit on Form 1116.
US Rental Property and the Treaty Credit
US real estate income is taxable first in the US. HMRC still taxes the profit, but it allows a credit for the US tax paid on it. When the UK rate is higher, a top-up remains. Clients often skip the UK return entirely because they assume the credit wipes it out. Yet the UK computation follows UK rules, including the mortgage interest restriction and no depreciation deduction. The UK profit therefore rarely equals the US figure.
Gains HMRC Taxes Without a US Credit
Gains on US shares cause the largest surprises. The US would not tax a non-citizen UK resident on portfolio share gains. Under the treaty, HMRC therefore gives no credit for the US tax you paid as a citizen. HMRC charges its full capital gains tax. Instead, the relief runs the other way. The US treats the gain as foreign-source, and you claim the UK tax against your US liability.
Case Study: A London Managing Director and a Schwab Account
The following example is illustrative, with figures rounded and converted at $1.25 to £1. It shows how an HMRC Wealthy Team letter can expose fully reported US income. It reflects a pattern we see often among American bankers in the City.
The Position Before the Letter
Daniel is a US citizen who moved to London in 2018 and has been UK resident and taxed on the arising basis since then. He earns about £540,000 a year through PAYE and files UK returns for his bonus and benefits. In addition, he holds a $2.1 million brokerage account in New York and a rented condominium in Boston. He reports both fully on his US returns and files his FBARs on time.
From 2019 to 2020 through 2024 to 2025, however, Daniel never put any US income on his UK returns. His US dividends averaged £32,000 a year. His Boston rental produced a UK-computed profit of about £24,000 a year. In 2022 to 2023, he sold technology shares for a gain of £144,000. In September 2026, he received an invitation from the HMRC Wealthy Team to meet his new Customer Compliance Manager. Nothing in the letter mentioned America.
Quantifying the UK Exposure
The dividends total £192,000 over six years. At the additional dividend rate of 39.35%, less the 15% treaty credit, the UK tax due is about 24.35%, or £46,752. The rental profits total £144,000. At 45%, less a credit for US federal tax at an effective 32%, the UK top-up is about 13%, or £18,720. The 2022 to 2023 gain, after the £12,300 annual exempt amount, attracts capital gains tax at 20%, or £26,340, with no US credit.
The total underpaid UK tax is therefore about £91,812 before interest. HMRC can reach every year involved. The offshore time limit in section 36A of the Taxes Management Act 1970 allows assessments up to 12 years back for offshore matters from 2015 to 2016. HMRC need not show carelessness. Furthermore, the United States sits in Category 1 of the offshore penalty regime, as HMRC's Compliance Handbook at CH112400 confirms. A careless penalty therefore follows the domestic ranges.
On a prompted basis, Daniel faces a penalty of 15% to 30%, or between £13,772 and £27,544. Had he disclosed through the Worldwide Disclosure Facility before the letter, the range would have started at 0%. That timing difference alone was worth up to £13,772 to him.
Recovering Tax From the IRS
The UK capital gains tax on the 2022 to 2023 sale is about $32,900. Daniel had paid US federal tax of roughly $27,000 on the same gain at 15%. Because the treaty re-sources the gain, he can claim the UK tax as a foreign tax credit on an amended 2022 return. The ten-year refund window in section 6511 for foreign tax credit claims keeps that year open. Meanwhile, the rules on foreign tax redeterminations in section 905(c) govern the notification.
As a result, Daniel recovers up to about $27,000 from the IRS, and the excess UK credit carries forward. Additional UK tax on his dividends may produce further US relief, subject to the Form 1116 limitation. His net cost across both countries therefore falls well below the headline UK figure. That only works when both sets of returns are prepared together, in the right order.
A Decision Framework Before You Reply to the HMRC Wealthy Team
We use three questions with every client who receives an HMRC Wealthy Team letter or expects one. Answer them in order, because each answer changes what you do next.
Question One: Is Every UK Return Complete?
Start with a full inventory of your US income for every UK tax year since you became resident. Compare it line by line with your UK returns. If anything is missing, the safest route is usually a disclosure before any meeting. For careless errors, that means the Worldwide Disclosure Facility. Where conduct may have been deliberate, however, the Contractual Disclosure Facility under Code of Practice 9 may fit better. Our guide to Code of Practice 9 for US filers explains.
HMRC's planned reform of error correction will also matter here. We cover it in our guide to the customer correction notice, which from April 2028 will turn a known but uncorrected error into deliberate behaviour.
Question Two: Do Both Countries' Records Match?
Next, reconcile your UK position with your US filings. Your FBAR records with FinCEN, your Form 8938 and your Form 1040 schedules already describe your accounts to the IRS. If you also have missed FBAR filings for UK accounts, fix them in the same exercise, using the guidance on the IRS FBAR page. Then make sure any statement you give HMRC about the same accounts uses the same values, dates and ownership.
This step protects you in both directions. A consistent record limits HMRC's room to infer concealment. Likewise, it avoids creating a UK document that contradicts a certification you have already signed for the IRS.
Question Three: Who Will Speak for You?
Finally, decide who attends any HMRC Wealthy Team meeting and what is in scope. Agree the agenda in writing, attend with a representative who understands both systems and keep a contemporaneous note. You are not obliged to attend a voluntary meeting. Nevertheless, a considered written response is usually wiser than silence, because silence can push HMRC towards a formal notice.
If a meeting goes ahead, answer questions about tax advice cautiously and, where privilege matters, with a lawyer involved. Above all, do not improvise answers about US structures from memory. A wrong figure stated confidently becomes part of HMRC's record.
How TaxYork Can Help With an HMRC Wealthy Team Approach
We prepare US and UK returns side by side. As a result, one team reconciles what the HMRC Wealthy Team may see with what the IRS already holds. Our work starts with a two-country inventory of income, gains and accounts for every year the HMRC Wealthy Team could still open. From there, we prepare missed UK tax returns or the matching disclosure, plus amended Form 1040-X claims with revised Form 1116 schedules. We also file any outstanding FBAR or Form 8938 reports through our FBAR and FATCA reporting service.
In addition, we prepare the treaty computations that decide how much of a UK settlement comes back from the IRS through our treaty relief and foreign tax credit service. Where years of US filings are also behind, our team handles the US tax returns for expats in the same engagement. As a result, both countries receive one consistent set of figures.
Conclusion: Reconcile First, Talk Second
The October 2026 plan makes the HMRC Wealthy Team's direction plain. It will connect more data, field more offshore specialists and test penalties more carefully, with firm dates in 2027, 2028 and 2030. For Americans in Britain, the exposure rarely lies in secret accounts. Instead, it lies in fully reported US income that never reached a UK return.
If the HMRC Wealthy Team contacts you, treat the letter as the last point at which your position can still look orderly. Reconcile every UK year against your US returns, correct what needs correcting, and then decide how to respond. Handled in that order, the US credits often recover a meaningful share of the UK cost. You can also read how HMRC already uses publication as a sanction in our guide to publishing details of deliberate defaulters.
Contact Us
Has HMRC written to you about your assets, or do your UK returns leave out US income? Book a consultation and we will map your position across both tax systems before you reply. You can also email hello@taxyork.com or call 020 3488 8606.
Disclaimer
This article provides general information for educational purposes only and does not constitute tax, legal or financial advice. Figures from HMRC's plan reflect its publication of 28 October 2026. HMRC has not confirmed every press report about the invitation letters, and treaty outcomes depend on individual facts. The case study is illustrative. Please take personalised professional advice before acting.