Two things that are easy to confuse. There is the tax return, which computes what is owed, and there is the informational reporting on accounts and assets, which is due whether or not anything is owed. In a jurisdiction that levies no personal income tax on salary, the local side may generate no personal return for that salary at all, so the annual exercise is the US return plus the reporting set. Both halves are prepared together, because the facts that support the exclusion claim on the return are the same facts that define the reporting.
Filing in both US and UAE — what do I file?
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US citizens in a jurisdiction that may levy no personal income tax on salary, which means the earned-income exclusion and housing amount do the work that a credit normally would. Two obligations, one income. A treaty allocates the tax; it does not consolidate the filing.
What has to be filed in each
US citizens in a jurisdiction that may levy no personal income tax on salary, which means the earned-income exclusion and housing amount do the work that a credit normally would.

When the rule breaks
The exclusion depends on a qualifying test being met, and the account and asset reporting continues regardless of whether any tax is owed.
Where to go from here
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on US ↔ UAE cross-border tax. If that describes your position, the next step is a short call — not a form.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Cross-border situations we are engaged for
Building an annual filing schedule for a relocating family
A family moving to the Emirates wanted to know what each year would require before they arrived rather than afterwards. We set out the two halves of the obligation, the return computing tax and the reporting on accounts and holdings, listed every filing each family member would generate, and tied each one to the document that supports it. The engagement produced a written annual schedule, a document checklist for the qualifying test and the housing amount, and a first filed year prepared against that schedule so later years follow the same shape.
Read how this one runsExcluded salary alongside investment income that was not
A client's employment income was fully covered by the exclusion and the earlier returns had stopped there. A portfolio held outside the Emirates had produced dividends and gains that the exclusion does not reach, and no local tax had been paid on them either. We identified which income the exclusion applies to and which it does not, computed the balance properly, and filed the reporting for the accounts concerned. The engagement produced corrected returns for the open years and a written split between covered and uncovered income.
Read how this one runsDeciding the reporting for accounts held with a non-filing spouse
A client held several accounts jointly with a spouse who was not a US filer, and the previous preparer had left them out on the basis that they were the spouse's. We established the ownership and signing position for each account, decided which had to be reported and on what basis, and documented why the remainder did not. The engagement produced the reporting set for the open years, a schedule of accounts with the decision recorded against each, and a position the couple can apply consistently as accounts are opened or closed.
Read how this one runsA prior return filed without its reporting set
A client's returns had been filed on time for several years with the salary properly excluded, but no account or asset reporting had ever accompanied them. Because the tax result was nil, nobody had asked. We inventoried the holdings, worked out which reporting obligations arose in each open year, and filed them against the returns already on record. The engagement produced the missing informational filings, a reconciliation between them and the returns, and an annual routine that prepares both halves together.
Read how this one runsSeparating salary, allowance and accommodation for one filing year
A client's package combined a base salary, a cash allowance and company accommodation, and all of it had been entered on the return as a single excluded figure. We separated the elements, established which fell within the earned-income exclusion and which had to be dealt with through the housing amount, and tied each to the contract and payment records behind it. The engagement produced a return in which every line traces to a document, and a summary the client can give an employer so future statements arrive in a usable form.
Read how this one runsAssembling a qualifying-test claim from reconstructed records
A client had qualified for the exclusion for years but had kept nothing beyond bank statements. A query on one year required the qualifying test to be demonstrated, and there was little on file to do it with. We reconstructed the presence record from passport stamps, airline records and payroll periods, set out what it showed, and filed the response. The engagement produced a documented qualifying position for the year in question, the working papers behind the reconstruction, and a simple record for the client to keep from then on.
Read how this one runsOne Salary, Two Countries Claiming It
A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
Read how this one runsA Retirement Plan That Grows Tax-Deferred in Only One Country
Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.
Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
US and UAE: further questions
Where the jurisdiction levies no personal income tax on employment income, there is generally no personal return computing tax on that salary, and so nothing to reconcile the US filing against. That is a genuine simplification of one side and a complication of the other: with no foreign tax to credit, the US return has to rely on the earned-income exclusion and the housing amount instead, and both depend on a qualifying test being met. Do not read the absence of a local return as the absence of an annual obligation.
It has to be claimed on the return, and the claim has to be supported. The exclusion depends on a qualifying test being met for the period claimed, so the filing carries the facts that establish the test as well as the arithmetic that follows from it. If the return is filed without the claim, or with a claim the facts do not support, the outcome changes substantially, because there is no foreign tax on salary sitting behind it as a fallback. Assemble the evidence while preparing the filing, not in response to a query.
The return is still required, and filing it is what puts the exclusion claim on record. A computation arriving at nothing owed is not the same as having no obligation, and the reporting on accounts and assets is unaffected by the result of the tax computation. There is a practical reason too: a continuous filed record makes each following year straightforward, while a gap has to be explained and repaired later. A continuous record costs less to maintain than a gap costs to put right.
The informational ones. Account and asset reporting continues regardless of whether any tax is owed, so the reporting set is prepared on the same timetable as a year with a liability. What varies with the tax result is only the tax computation itself. In this corridor that distinction does most of the damage, because the salary is often fully covered and the person reasonably concludes the year needs nothing at all. Build the annual file around what you hold, not around what you owe.
Keep the papers that prove the things your filing depends on: the assignment start date, a travel and presence record kept as the year runs for the qualifying test, the tenancy contract and payment evidence for the housing amount, the employment contract and any employer letter describing accommodation or allowances, and year-end statements for every account and holding. None of that arrives from a local tax authority in a jurisdiction that does not tax your salary, which means nobody will produce it for you later. Collect it as you go.
Double taxation means the same income being taxed by two authorities. It comes in two forms: juridical, where two countries each tax one person on one amount, and economic, where two different people are taxed on the same underlying profit — a company on its earnings and a shareholder on the dividend paid out of them. Relief comes from a treaty, a foreign tax credit, or an exemption, and which one applies depends on the income type. How to avoid double taxation sets out the routes.
Cross-border tax is what applies when income, assets or people touch more than one tax system at once — someone living in one country and earning in another, a company selling or hiring abroad, a family holding property in a second country. The work is rarely one country's rules applied harder; it is reconciling two sets of rules and claiming the relief that stops the same income being taxed twice at full rates. See what we do.



