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Where Taxpayers and Advisers Meet

Search found 67 matches

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by guya
Mon Jan 25, 2010 10:19 pm
Forum: International Tax
Topic: Foreign Income and SA100
Replies: 1
Views: 583

Re: Foreign Income and SA100

Phil - generally speaking this is a moot point because most income is resourced as foreign on the US return under the Treaty and the US gives credit for the UK tax - not the other way about.
by guya
Mon Jan 25, 2010 10:17 pm
Forum: International Tax
Topic: Split Year Treatment
Replies: 2
Views: 1009

Re: Split Year Treatment

You may of course be treaty resident in the other country given that you were present there most of the year.
by guya
Mon Jan 25, 2010 10:16 pm
Forum: International Tax
Topic: Double Tax Relief
Replies: 4
Views: 866

Re: Double Tax Relief

Income from an S-Corp is - broadly speaking - taxed on distributions so there will be double taxation unless the company is in any case UK resident under general principles.

You will want to observe such items as section 739 depending on amounts, dates etc as this is not a remittance based issue.
by guya
Fri Jan 08, 2010 11:19 pm
Forum: International Tax
Topic: Taxes upon leaving the UK
Replies: 2
Views: 709

Re: Taxes upon leaving the UK

Your adviser is correct.

If you paying UK tax on the remittance basis - or claiming R/NOR status - the UK does not give you a personal allowance.

Sorry but the law changed effective 6 April 2008. AJHenderson is perhaps not up to date.
by guya
Thu Jan 07, 2010 10:12 pm
Forum: International Tax
Topic: working in angola living in uk tax help
Replies: 2
Views: 1162

Re: working in angola living in uk tax help

This is a standard rotational assignment in the oil/gas industry.

gazprom remains UK resident but gets to claim the foreign tax as a credit on the foreign pages of the UK return.

Is the employer not taking care of this under a tax protection agreement?
by guya
Sun Jan 03, 2010 1:23 pm
Forum: International Tax
Topic: UK Resident working online for a US company
Replies: 2
Views: 727

Re: UK Resident working online for a US company

When you live in the UK you and the employment will become subject to English (or Scottish) employment law. The concept of self-employment is - broadly speaking - more restrictive here in the UK than in the United States. Your employment will thus become subject to local employment law here in the U...
by guya
Sat Jan 02, 2010 12:20 am
Forum: International Tax
Topic: US Citizen Retiring in England
Replies: 19
Views: 11931

Re: US Citizen Retiring in England

The IRS answer will depend on whether you elect the remittance basis on a UK return and - if not - if you elect into the UK/US treaty on a UK return. This should have read: The IRA answer will depend on whether you elect the remittance basis on a UK return and - if not - if you elect into the UK/US...
by guya
Sat Jan 02, 2010 12:19 am
Forum: International Tax
Topic: US Citizen Retiring in England
Replies: 19
Views: 11931

Re: US Citizen Retiring in England

OK so far... but I see no reason why the UK would not tax the disability pay ... foreign currency (eg American dollars) is a chargeable asset for UK capital gains tax purposes where is why disposal of dollars could cause a UK capital gains tax charge with horrendous maths to actually prepare a UK re...
by guya
Fri Jan 01, 2010 11:01 pm
Forum: International Tax
Topic: US Citizen Retiring in England
Replies: 19
Views: 11931

Re: US Citizen Retiring in England

I agree that the question was clear and that Michael is correct here. The saving clause in the treaty is over-ridden for both US Social Security and Government Pensions so there is indeed only US tax on these - not UK - even if remitted to the UK. You would file Form 8833 with the US return and make...
by guya
Tue Dec 22, 2009 9:25 am
Forum: International Tax
Topic: Paid in UK for overseas work while still in UK
Replies: 2
Views: 671

Re: Paid in UK for overseas work while still in UK

Assuming you worked in the UK in October, November & December the income is taxable in the UK.

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