They started it all with Stonewall, but we've left them way behind now. JAMES COLLARD, just back from New York's `Out' magazine, wonders why
Oh my Gaaaaad!," someone gasps. "You can show that on primetime TV?" It's spring this year, in the Manhattan offices of Out magazine, the gay and lesbian glossy I then edited, and we're watching Channel 4's Queer As Folk. The young gay Americans I work with are amazed: full-on gay sex scenes, drugs, lots of rude words - gays behaving badly. As a gay Englishman I feel a glow of patriotic pride. An actor says the "C" word - I'm thrilled. There's a buggery shot - I'm ecstatic. And when the camera pans across a crowd of men and women, straight and gay, ripping up the dance-floor, I want to run around shouting "Yes, Britannia is cool!"

When I moved from Britain to America early in 1998, I left a country where to be gay was becoming less controversial by the day, where Lily Savage was seen as family entertainment and gay people played roles in British public life that were unimaginable in America. MPs such as Chris Smith, Nick Brown and Stephen Twigg were openly gay.

I've now returned to a country where gay acceptance has advanced still further. A "mixed", gay-friendly nightlife flourishes. Michael Portillo's revelations of youthful dabbling are greeted with a shrug of public indifference. Even the Conservative Association at Kensington & Chelsea, surely as conservative as they come, was unruffled enough to select him last week as its parliamentary candidate. In the past month, a raft of gay legislation is set to deliver new property and family rights to gays partners. The Lord Chief Justice himself last week declared that these reforms were "desirable and probably overdue".

It's a different story in the US. Thirty years after Stonewall put America at the forefront of the gay rights movement, Britain has left them standing. Gay people with real power are thin on the ground in the Clinton administration. In an ongoing murder trial, lawyers attempted to use "gay panic" as a defence, stating that the defendant was provoked to violence by homosexual advances. The judge rejected this defence last week, but the ensuing controversy has reverberated around America.

On TV, Ally McBeal has managed to kiss with a female colleague without the sky falling in, but when Ellen Degeneres came out in her sitcom, viewing figures collapsed. The latest trailblazer, Will & Grace, a sitcom about a straight woman and her gay roomie, finds poor Will after 13 weeks yet to be allowed to kiss a man, let alone have sex with one. American TV execs don't want to frighten the conservative viewing public, and advertisers. Even gay viewers are hard to please - with so few representations of homosexuality, they demand role models, not the cheerful hedonists we saw on Queer As Folk.

Of course, Americans tend to be more serious than Brits anyway - when I moved there, I noticed that while they smile more than we do, they don't laugh as much. One of the main differences I found going from Attitude, a British gay magazine, to Out was that any attempt at playfulness represents fiddling while Rome burns for some gay Americans.

Constant campaigning drains energy. It requires a more serious approach to life. It's hard work, all those cheesy benefits at 300 bucks a plate, rallying the troops with speeches, celebrating role models, signaling ordinary Americanness by standing for the Star Spangled Banner. The campaigners do vital work, but after my tenth or so benefit in the huge banqueting hall of some hotel in New York, LA or DC, I began to feel as if I was participating in a genteel, moneyed, version of the Intifada.

The most striking difference I found in New York was one of mood: there's a kind of embattled quality to gay life in America we no longer have in Britain. Lesbian New York writer Stacey D'Erasmo, recently in London on assignment, agrees. "What was really astonishing was this quality of exuberance, unwoundedness and joy," she says, "It inspired a poignant feeling in me, because in the States in the last 15 years, gay culture has had a very rough ride - and it shows. We are angrier and more organised, but we're also sadder. What fairy dust was sprinkled on Britain that America missed out on?"

Perhaps the answer lies in what Britain lacks but America must contend with - the powerful and highly organised religious right. Every step forward - a prime-time kiss, a hard-won constitutional or legal ruling, a city council granting spousal benefits to gay couples, a move to include sexual orientation in a state's "hate crime" legislation - triggers howls of protest, concerted lobbying and reactionary ballot initiatives aimed at overturning gay-friendly legislation, led by the religious right. The argument for acceptance isn't just far from being won in the US - it may never be won. You simply can't debate with the Gospel truth. In the UK, while bad things happen, equality seems to be just behind a creaky old door - a few sharp kicks and we're through. In America, no matter how much gay people shove, the Christians on the other side shove harder.

I began to feel that American gay culture, which for so long led the rest of the world, was stuck in some endless, rather tearful coming-out party. Britain, meanwhile, has moved on. Writers like Paul Burston and Mark Simpson began sophisticated and provocative "post-gay" and "anti- gay" critiques that chipped away at that great American shibboleth, the gay identity. When I made the mistake of voicing some of these opinions at New York's New School, I got a bollocking from gay activists, who feel there isn't the room for that kind of fancy footwork. While Simpson puts this down to America being "a more conformist country than Switzerland", the view across the Atlantic is a different one. As D'Erasmo puts it, "In America we are forced to do gay lib over and over and over again. It gets boring - but it has to be done. What are the options?"

James Collard is now contributing writer at `Out' and writes for the `New York Times'.