Foreign Income Tax Deduction on Non-resident trusts

Foreign Income Tax Deduction on Non-resident trusts

Postby luvbritain on Sun Dec 18, 2011 8:22 pm

I am a US citizen considering coming to the UK when I retire as ordinarlily resident and non-dom. I need guidance on the following:

1. After my folks are gone, my brother and I will be beneficiaries of annual distributions from a non-resident, Irrevocalbe Charitable Remainder Trust . I think that this is comparable to a "possession trust" (e.g., Trustees cannot decide when, to whom, or how much is dispersed). It appears that the USA / UK Double Taxation does not offer a foreign tax credit for trust income. Can I still take a deduction for taxes paid in the USA on trust income when I file UK income taxes? How would I calculate the deduction? An example would be really helpful.

2. Also, I will be using the Remittance Basis. If available, can I take a foreign tax deduction based on US taxes paid (maybe at a %) when I file UK taxes on the Remittance Basis?

Any help in this area would be really helpful. Thanks.
luvbritain
 
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Joined: Sun Dec 18, 2011 8:07 pm

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