Today I wanted to take a look at the taxes of both the United States and the United Kingdom, and compare them to each other, and see who ends up being "better off", if any at all.
I'll just put my thoughts, some might be biased, some not. I'll let you be the overall judge, although I have set out some criteria below.
Please, please let me know your own thoughts in the comments at the end. I'd love to get everyones perspectives on all this.
Obviously talking about taxes is not the most fun subject in the world, but if you're genuinely interested in finding out about standards and costs of living between different places, it makes for interesting discussion.
I know that there isn't nearly enough good discussion on these kinds of things for newbie immigrants like myself, and it is something that seems daunting when you move to a new place. So I write this all with the hope that I can at least assist someone out there, even if just one question is answered by all this, it has been worth it.
Rules and Criteria For My Arguments
I'm not a business person, or qualified in accountancy of any kind, but I have done my research, and where possible, I will back up all my points with evidence. I won't just put something out there and make assumptions. I'll make it as factually accurate as I can.
I am going to write this from my point of view, as a fully capable, young adult who currently works in the UK. I think this will offer a fair comparison to most adults who have a regular job and income.
Obviously everyone's personal circumstances are slightly different, but we'll just go with the fact that I am a regular working adult.
Direct Taxes
Let's start with what I will refer to as a direct tax. Like I said, I'm no accountant, so if that's not a "technical term", then so be it, but that's what I'm calling this first category.
Direct taxes are taxes which are paid regularly, directly to the government. They immediately affect us as they are immediately deducted by whatever means, or are required to be paid immediately when billed.
Income Tax in the UK
Of course income tax on earnings is the biggest direct tax of all, and the one that affects nearly everybody who has ever worked.
Income tax rates in the UK are high generally, but more for higher income earners, and can go from 20%, all the way up to 45%.
For a regular working adult like myself, the current income tax rate in the UK is set at 20% on all earnings over £9440. This means that I can earn £9440 and not pay tax, anything over this amount is taxed at 20% (on just the excess amount, it does not work retroactively to tax all my income).
For anyone who is employed in the UK, taxes are worked out and deducted automatically from your salary/payslip/pay check. Nobody ever has to file a tax return if you're employed.
It's that simple. (We won't go down the route of self-employed, as that's not the point of this right now.)
If underpayments are required, HM Revenue and Customs normally send a letter informing you of how much is owed, and what options you have to pay the underpayment back. Usually you will be offered to be able to pay it back as part of your next tax year in your salary (your tax code will change and you will pay slightly more for however long it takes to make the repayment).
If overpayments are made, HM Revenue and Customs will automatically send you a cheque.
It should be noted that these instances do not happen often. If you change jobs and your new tax code isn't entered correctly by your employer then it may alter something, but that is unlikely.
If you are married or in a Civil Partnership, there is Married Couples Allowance. The rules of which seem complicated to me, but again, this is usually worked out automatically. It basically come down to that you should be paying slightly less tax in your salary, because you're married/CP'd.
It should be noted also that if you're retired, on a low income, disabled, and a multitude of other scenarios, the same applies. Your circumstances are all automatically calculated by the HMRC, and you shouldn't have to file anything. You might get a letter from time to time asking to prove your circumstances are still the same (for example, if you're on a low income, single parent etc), but that's about it.
In summary, if you work, and have a regular salary, or are retired or receive a permanent benefit (disabled etc), you'll be taxed in your salary/benefit, and never have to worry about filing anything else. Ever.
Federal Income Tax in the US
In the US, from my understanding, income tax is much more complicated.
For a start, everybody pays tax, regardless of income level. When I looked at the Federal Income Tax rates it seems that you have to pay a different percentage of tax for each level of income you earn.
For example, a single person who earns $25000 would pay 10% tax on anything from $0 to $8925, then 15% on anything else up to the $25000.
The tax rates also vary if you are filing as a single person, married filing together, married filing separately, or even as a household if you have dependants.
I also understand that a basic amount of tax is taken from salaries, but American still have to file anyway, for anything that is missed by the salary deduction and any adjustments that the IRS do not know about (income from other sources, bonuses, savings, etc).
If you owe anything, then you have to pay it with your returns, or if anything is owed, you can claim it back.
But of course, it isn't that simple in reality. As I mentioned, you could have some sort of adjustment, which could be in the form of an allowance/deduction, that means that you pay no tax on the first X-amount, for example $5000, and then 10% on $5000 to 13925 ($8925+$5000). There are a whole manner of scenarios as to why this can happen, such having children, medical expenses, interest payments on your home... The list goes on, and can get very complicated.
Jon admittedly did try to explain it all to me more accurately, and I tried to cover it the best I could here, but to explain it all would simply not be possible!
This is of course just for Federal Income Tax.
Then we come to State Income Tax.
State Income Tax in the US
You have filed your Federal Income Taxes, and you're done, right? Wrong. You also have to pay state taxes!
State income taxes can be mind-bogglingly complicated. I googled to see what I could find out about Maryland taxes, as that's where Jon and I will be living together, and I have to say, I was really lost.
You might think I'm trying to add a biased spin to this, but I'm really not. I wanted to make it sound simple, but all I came up against was long, complicated webpages, online leaflets and pages of numbers and percentages.
Eventually I found a site that listed them all by state. Seven states pay none, remarkably.
And from what I could make out, seven pay a flat rate, regardless of income. The rest, plus DC, pay a variable rate depending on income.
As with Federal Income Taxes, what you pay can depend on varying circumstances, from dependants, other sources of income etc.
Based on my example earlier of someone who earns $25000, in addition to the Federal taxes of up to 15%, that person would also have to pay 4.75% on earnings over $3000, plus an extra $90 (don't even ask!), PLUS county taxes, of at least 1.25% (based on the "cheapest" county to live in)!
So to live in the "cheapest" county in Maryland, your income taxes all combined (including Federal) at looking to be at least 21% - for a low income worker!
That's already 1% more than the UK. I realise that for Federal taxes the amount is staggered, but still, 21% is a lot, and the threshold is a lot less than the £9440 tax free allowance of the UK.
Also, of course, I know there are deductions that might bring your taxes down (dependants etc), but I'm trying to keep this simple - which as you can see is a challenge in itself!
Living Outside the US
Of course, if you're a US Citizen and you live outside the US, you don't escape the tax system that easily!
If you are a US Citizen, you are still required to file taxes in the US, even if you don't owe anything!
And get this, if the equivalent of any income tax you pay in your country of residence is less than the US rate, then you have to pay the US the difference! Even if you are not living or working in the US, and haven't done for several years, you are still basically penalised and taxed on your hard earned cash!
To my knowledge, no other country makes their citizens do this.
Summary
All I can say is, what a nightmare! I hope that all made sense, and if not - then you can hopefully see how confused I have been by it all!
It isn't just the percentages and numbers that cause me issue though; it's the fact that you have to go through all of this in the first place.
It seems like one big hassle to sit and work all these figures out for yourself, buy specialised software to do the calculations, and even in some cases hire a lawyer - just to pay taxes!
The US government do not make things easy!
Filing my own taxes (albeit with Jon of course) is the one thing that I think I am going to find really strange and annoying about moving to the US. I realise Jon has had a lot of experience with this, but it's not something I have ever had to deal with, and it's a little daunting.
I can't guarantee that either system is better or more affordable than another, but having been with Jon for nearly 6 years, and having lived in the UK all my life, I personally have to go with the UK system.
Some might say that I'm being biased, but why would I want the hassle of such a system, like the US?
It just seems like one big headache!
I said I'd back up my evidence, and so at the end of this blog post, I have listed all the websites I used as a point of reference.
Please do let me know your thoughts, in the comments below.
In my next article I'll be talking about the NHS, Health Insurance, Social Security, Medicare and Medicaid.
Dan.
*
HM Revenue and Customs - http://www.hmrc.gov.uk/incometax/personal-allow.htm
About.com article on US Federal Tax Rates - http://taxes.about.com/od/Federal-Income-Taxes/qt/Tax-Rates-For-The-2013-Tax-Year.htm
Wikipedia page for State Income Taxes - http://en.wikipedia.org/wiki/State_income_tax
About.com article on State Income Taxes - http://taxes.about.com/od/statetaxes/a/highest-state-income-tax-rates.htm
TaxAdmin.org's document showing all state tax rates - http://www.taxadmin.org/fta/rate/ind_inc.pdf
Comptroller Maryland Official Tax Information Sheet - http://taxes.marylandtaxes.com/Resource_Library/Tax_Publications/Tax_Facts/Withholding_Tax_Facts/Withholding_tax_facts_2013.pdf
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