The US tax architecture is different

US persons (US citizens, green card holders, and certain long-term residents) are subject to worldwide taxation regardless of residence. Moving to the UAE does not, by itself, eliminate US federal income tax obligations. The challenge for a US person relocating to Dubai is therefore not to escape US taxation, but to optimise within it via the Foreign Earned Income Exclusion, foreign tax credits, and treaty positions.

Foreign Earned Income Exclusion (FEIE)

Under IRC §911, a qualifying US person may exclude a tax-year-specific amount of foreign earned income from US federal taxation, plus a housing exclusion. For tax year 2025, the FEIE amount is US$130,000; for tax year 2026, it is US$132,900. Eligibility requires either the bona fide residence test (resident of a foreign country for an uninterrupted tax year) or the physical presence test (330 days outside the US over any 12-month period).

For a US person taking up UAE residency, the FEIE is the primary planning tool, particularly given the UAE's absence of personal income tax.

FATCA reporting

The Foreign Account Tax Compliance Act (FATCA) requires US persons to disclose foreign financial accounts and certain assets. Two parallel obligations:

• Form 8938 (FATCA reporting): filed with the IRS as part of Form 1040. Threshold for unmarried persons living abroad: US$200,000 on the last day of the year or US$300,000 at any time during the year.
• FBAR (FinCEN Form 114): filed with FinCEN if aggregate foreign financial accounts exceed US$10,000 at any time. Filed online via BSA E-Filing.

The UAE is a FATCA partner jurisdiction since 2015 (Model 1 IGA). UAE banks systematically report US person accounts to the FTA, which transmits the data to the IRS.

US-UAE absence of treaty

The United States and the United Arab Emirates have no comprehensive income tax treaty in force. This produces several consequences:

• No reduced withholding rates on cross-border dividends, interest, royalties between the two States.
• No tie-breaker for dual residency conflicts (irrelevant in practice given UAE absence of personal income tax, but relevant for corporate residency).
• Foreign tax credit (FTC) under §901 remains available but limited to the rare instances of UAE tax effectively paid.

There is no bilateral income tax treaty between the United States and the United Arab Emirates. The only intergovernmental instrument in force is the FATCA Intergovernmental Agreement (Model 1 IGA) signed on 17 June 2015, under which the UAE reports US person accounts to the IRS.

UAE Corporate Tax exposure for US persons

UAE Corporate Tax applies to financial years / Tax Periods starting on or after 1 June 2023 under Federal Decree-Law No. 47 of 2022. UAE Corporate Tax may be relevant for US foreign tax credit or anti-deferral purposes only depending on the structure, the taxpayer bearing the tax, and the applicable US rules. It should not be presented as an automatic direct credit on an individual Form 1040 merely because a UAE company pays Corporate Tax. The analysis may involve, depending on the case, a sole proprietorship, disregarded entity, corporation, CFC / GILTI rules, section 960, section 962, distributions and Form 1116 limitations.

Renunciation of citizenship: the exit tax

A US person who renounces US citizenship may trigger the covered expatriate exit tax under IRC §877A. Triggers include:

• Net worth ≥ US$2 million on the date of expatriation;
• Average annual net income tax meeting the tax-year threshold published by the IRS — for 2025, US$206,000 — for the 5 prior years;
• Failure to certify 5 years of US tax compliance.

The covered expatriate is treated as having sold all worldwide assets at fair market value the day before expatriation, subject to the exclusion amount applicable for the tax year — US$890,000 for 2025. The 2026 and later thresholds should be checked against the latest IRS inflation adjustments and Form 8854 instructions before use. The procedure is complex and requires careful planning.

Practical roadmap for a US-to-UAE move

1. Establish bona fide residence or physical presence in the UAE to qualify for FEIE.
2. File annual Form 8938, FBAR, Form 1040 with FEIE election (Form 2555) and FTC where applicable (Form 1116).
3. Structure UAE business with awareness of CFC, GILTI, Subpart F rules for US persons holding UAE corporations.
4. Consider Roth IRA conversions, US municipal bond positions, and other US-favoured investments while UAE resident.
5. Coordinate with a US Enrolled Agent or CPA, a US international tax counsel, and a UAE counsel.
6. If long-term, evaluate renunciation strategy with full §877A exit tax modelling.