Buying in New York vs back in the UK: co-op boards, mansion tax and HMRC
New York doesn't care about your passport, but a co-op board might. Back in Blighty anyone can buy, though living abroad and owning a Brooklyn condo can both push up your stamp duty.
The short version
- No foreign-buyer ban or surcharge in New York. A Brit on an E-2, an L-1 or a green card buys on the same tax terms as a New Yorker. The catch is the co-op board.
- Purchase taxes are modest below US$1 million. City and state transfer taxes usually fall on the seller, and the buyer's 1% mansion tax starts at US$1 million [8][9].
- In England, a non-resident pays a 2% stamp duty surcharge, and owning a home worth £40,000 or more anywhere in the world adds the 5% higher rate [1][2].
- Selling a UK home from New York means a UK return within 60 days of completion, and the IRS taxes the same gain [3][10].
- Selling a New York home after you've left usually means 15% withheld at closing under FIRPTA [10].
Pound conversions use the Bank of England spot rate of 5 November 2026 (£1 = USD 1.35).
What a Brit can buy in New York, compared
Back home, buying a flat usually means a long lease, a freeholder and a service charge. New York has two main models instead.
- Co-ops dominate the older stock in Manhattan and much of Brooklyn and Queens. You buy shares in the corporation that owns the building and get a proprietary lease on your flat. A board of residents vets your finances, interviews you and can say no without giving a reason. Thin US credit, income in pounds and plans to sublet are the usual sticking points.
- Condos are real property: you own the unit outright plus a share of the common parts. There's usually no board interview, just a building right of first refusal, and subletting is generally easier.
- Houses (a brownstone in Park Slope, a semi in Queens) are owned outright, like a freehold back home.
There's no federal or state rule stopping a foreigner buying any of these. Our guide to co-ops vs condos in New York goes through the board package.
In England and Wales anyone can buy too. Houses are normally freehold and most flats leasehold, with a lease length, service charge and freeholder to check.
Upfront costs side by side
To compare like with like we've used the same money: £300,000, which is about US$404,000. These are our sums from the published rates, before attorney fees, title insurance, surveys and lender costs.
| New York City: condo, US$404,000 | England: house, £300,000 | |
|---|---|---|
| Main purchase tax | NYC real property transfer tax at 1%: US$4,040 (about £3,000), usually the seller's [9] | Stamp Duty Land Tax: £5,000 at standard rates [1] |
| State tax | NYS transfer tax at 0.4%: US$1,616 (about £1,200), paid by the seller [8] | None |
| Foreign or non-resident extra | None | 2% non-resident surcharge: £6,000 more [1] |
| "Mansion" or higher-value tax | Buyer pays 1% at US$1 million (about £742,000) and up; extra supplemental tax from US$2 million [8] | Bands rise to 12% over £1.5 million [1] |
| Owning another home | No extra | 5% higher rate if you keep a home worth £40,000+ anywhere [2] |
| Buyer's tax bill | Nil on a resale, if the seller pays as usual | £11,000 as a non-resident, £26,000 if you also keep a US home |
So at this price the buyer often pays no purchase tax at all in New York, though two things change the picture:
- New-build condos. Developers often ask buyers to pay the seller's transfer taxes. Read the offering plan.
- Mortgage recording tax. Taking out a mortgage on a condo or house brings a combined state and city tax of just under 2% of the loan, depending on its size. Co-op share loans aren't recorded mortgages, so co-op buyers skip it.
Back home, the 5% higher rate is the one that surprises people. Buy in Bristol while keeping your Brooklyn condo and HMRC treats the Bristol house as an additional home, because the test counts property anywhere in the world [2]. Living abroad as well? That's both surcharges: £26,000 on £300,000. A UK resident with another home pays £20,000; a non-resident first-time buyer with no other home pays £6,000 [1]. You can reclaim the 2% if you spend 183 days in the UK within a year of buying, and the 5% if you sell your previous main home within three years [1][2].
Scotland and Wales differ. Neither has a non-resident surcharge. In Scotland, LBTT on £300,000 is £4,600 for 2026–27, plus an 8% Additional Dwelling Supplement (£24,000) if you'll own another home. In Wales, LTT on £300,000 is £4,500 at main rates, or £19,950 at the higher residential rates.
Financing: US lender or UK lender?
In New York, your UK credit history counts for nothing. Lenders look at a US salary, a few payslips and your visa, and many want a bigger deposit from newcomers. Co-op boards add their own rules on top: a minimum deposit and cash left over after closing, set building by building. Some banks with UK and US arms will lend on your wider relationship. The 30-year fixed-rate mortgage, rare back home, is normal here.
Back in the UK, many high-street lenders won't lend to someone living in the US or won't count dollar income. A smaller group of specialist and private-bank lenders does, usually with a bigger deposit. Repaying a sterling mortgage from dollar income can make it a "foreign currency loan" under FCA rules, with warnings when the exchange rate moves a long way. Our guide to UK mortgages for Brits living abroad explains more.
Owning it: property tax and running costs
In New York City the Department of Finance taxes property by class. For tax year 2026 the rates are 19.843% for Class 1 (most one- to three-family houses) and 12.439% for Class 2 (most co-ops and condos), applied to an assessed value that's a fraction of market value [9]. Bills vary widely by building, so ask for the last two years before you bid. On top come condo common charges, or co-op maintenance, which already includes your share of the building's tax.
In the UK you'll pay council tax. If the house sits empty as a furnished second home, councils in England can charge a premium of up to 100% from April 2025, so up to double the bill, with exceptions such as up to 12 months while it's marketed for sale or let [5].
Letting the UK home while you're in New York? Under the Non-Resident Landlord Scheme your letting agent, or a tenant paying more than £100 a week, takes basic rate tax off the rent unless HMRC approves you on form NRL1 [6]. You still file a Self Assessment return, and as a US tax resident you report the same rent to the IRS, with credit for UK tax. See renting out your UK home.
Tax when you sell
The US side
- Your New York home while you live there. If you've owned it and lived in it for two of the five years before the sale, you can exclude up to US$250,000 of gain, or US$500,000 for most joint filers [10]. Beyond that, the gain is taxed federally, and by New York State and City.
- Your UK home. Green card holders and most Brits working in New York are US tax residents, taxed on worldwide gains. The same exclusion can cover a UK home you lived in for two of the last five years, which often runs out about three years after you move. The gain is measured in dollars, so currency moves change it.
- Selling after you've left the US. A seller who's no longer US tax resident usually has 15% of the price withheld at closing under FIRPTA, with narrow exceptions for cheaper homes the buyer will live in [10]. You then file a US return to settle the real bill. New York State also expects estimated tax from non-resident sellers at closing.
The UK side
- Selling a UK home while you live in New York: non-residents pay UK capital gains tax on UK property and must report every sale within 60 days of completion, even with no tax due [3]. For homes owned before April 2015 you generally only pay on growth since 5 April 2015. Rates are 18% and 24% for 2026–27, with a £3,000 annual exempt amount. Private residence relief can still cover the years you lived there plus the final nine months.
- Selling the New York home once you're back in the UK: a UK resident pays capital gains tax on overseas property and may claim relief for tax paid abroad [4]. For years when you're not tax resident in the US, private residence relief on that flat generally needs 90 nights a year there [4].
- The UK–US double taxation convention, applied by the UK from 6 April 2003, sorts out who taxes first [7]. Broadly, the country where the property sits taxes first and the other gives credit.
If your partner is American, our sister site ExpatStateside explains the hidden US tax on currency gains on a foreign mortgage, which can catch a US tax resident paying off a sterling mortgage. A tax adviser who knows both countries can check your case.
Which makes sense for whom
- On a two- or three-year posting. Renting usually wins. Closing costs, board packages and FIRPTA withholding on the way out make a short stint expensive.
- Settled with a green card. Buying works like it does for a local, and the US$250,000 exclusion can shelter a good chunk of gain.
- Keeping the house in Bristol. Let it with NRL1 in place and remember the US taxes the rent too. The US exclusion on that house fades about three years after you leave it.
- Planning to come home. Selling New York while you're still US resident avoids FIRPTA withholding; selling after you've gone means more paperwork.
Before you put an offer on anything, ask which buildings were kind to newcomers in our community group for Brits in the US.
Sources
- GOV.UK: Stamp Duty Land Tax, residential property rates
- GOV.UK: Stamp Duty Land Tax, buying an additional residential property
- GOV.UK: Report and pay your Capital Gains Tax, if you sold a property in the UK
- GOV.UK: Tax when you sell property, selling overseas property and HMRC Capital Gains Manual CG64582: the 90-day test
- GOV.UK: Council tax premiums on long-term empty homes and second homes
- HMRC Property Income Manual PIM4810: the Non-Resident Landlord Scheme and HMRC: Apply as an individual to receive UK rental income without UK tax deducted (form NRL1)
- GOV.UK: USA tax treaties
- NYS Department of Taxation and Finance: Real estate transfer tax
- NYC Department of Finance: Real Property Transfer Tax and Property tax rates
- IRS: FIRPTA withholding and Topic 701, Sale of your home