GUEST COMMENT: From a tax perspective, Wall Street is a far worse option than London

If you work in financial services, the UK tax system has become increasingly unappealing. In the past 18 months we've had tighter rules on non-doms, a 50% tax rate, and now a new penal tax on bonuses. Surely there must be a better place to go? Geneva and Dubai beckon, but - being realistic - if you're not going to be based in London then New York is where the action is.

Unfortunately, and as news of today's US bank levy shows, the US is no more immune to tax changes than the UK. Admittedly, the levy looks like impacting corporations only, but the US is also disadvantageous from an individual tax perspective. US tax rates are certainly lower than in the UK, with the top federal rate of income tax at 35%, but state taxes apply on top of this and do you really want to get into their clutches.

Nor do the disadvantages of shifting to Wall Street stop there. Firstly, you can find yourself becoming a resident (for tax purposes) in the US more easily than in the UK. This is because it is not just the days you spend in a particular year that count towards US residency, but also one third of those in the previous year and one 6th of the year before that.

In addition, you will always be caught in the US tax system if you have a green card. And if you want to work in the States, a green card will probably be required.

This is when the problems really start.

Despite the recent rule changes, in the UK it's still possible for a non-dom to avoid tax on their overseas income and gains for the first seven years they're here and, after that, through payment of a 30,000 remittance basis charge. In the USA, once in the net, you are automatically caught for your worldwide income and gains without any exceptions.

On this test alone, the US still makes the UK look like a tax haven for the wealthy non-doms.

Particular problems arise if you become resident in the US while holding shares in companies overseas. The so-called controlled foreign company rules apply in the US when a resident citizen owns more than 50% of the shares in a non-US resident company. This can result in the imposition of a personal income tax bill on the profits of such a company. For this reason, there are extensive filing requirements imposed on US residents in respect of their overseas interests. This in itself can be a significant administrative burden.

And finally, escaping the US net can be more difficult than escaping the UK tax net. We may look back on 2009/10 as the low point in the way the UK treats the financial services industry. The future is certainly not rosy, but you'll probably be a lot better off here than if you move to the USA.