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Where Taxpayers and Advisers Meet

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by DavidTreitel
Tue Oct 01, 2019 7:02 pm
Forum: Income Tax
Topic: taxation of income from a USA IRA distribution
Replies: 3
Views: 164

Re: taxation of income from a USA IRA distribution

Assuming you are electing to treat the IRA as a pension plan, the UK has the primary right to charge tax on the gross distribution. Withholding tax is not a final tax and is not creditable in the UK.
by DavidTreitel
Wed Sep 25, 2019 12:43 pm
Forum: International Tax
Topic: Is my US payment taxable by the IRS?
Replies: 1
Views: 157

Re: Is my US payment taxable by the IRS?

You did not do the work. A UK limited company you control did the work. How is that company taxed in your country of residence?
by DavidTreitel
Fri Aug 23, 2019 11:58 am
Forum: International Tax
Topic: Uk citizen setting up a remote business in the usa
Replies: 2
Views: 3770

Re: Uk citizen setting up a remote business in the usa

This 2015 article discusses the Anson case in detail: https://www.taxadvisermagazine.com/article/certainty-uncertainty In essence, a US domestic LLC would be an extremely unusual entity to select for a UK resident. With the business described I would equally be worried about management & control. Th...
by DavidTreitel
Tue Aug 13, 2019 8:08 pm
Forum: International Tax
Topic: UK taxation of USA pensions
Replies: 4
Views: 5317

Re: UK taxation of USA pensions

It is rare, very rare, for US pension income to be completely exempt from UK tax. Generally speaking the UK has the primary taxing right. 1.What is your UK client's domicile status? 2. If domiciled outside the UK is the client electing to claim the remittance basis? 3. Are these pensions government ...
by DavidTreitel
Wed Aug 07, 2019 8:47 am
Forum: International Tax
Topic: Exchange rate and time of exchange for tax
Replies: 3
Views: 4674

Re: Exchange rate and time of exchange for tax

The exchange rate is the date the dividends were due - January 2019. The income is UK taxable in 2018-19. You will have had 15% US tax withheld and can claim double tax relief in the UK for that US tax.
by DavidTreitel
Mon Aug 05, 2019 6:22 pm
Forum: International Tax
Topic: How does a US dual status tax return work?
Replies: 4
Views: 4309

Re: How does a US dual status tax return work?

Geordie - the answer is not straightforward; the worst case scenario may help. It is 37% (the top Federal tax rate) plus a 10% penalty, plus State income tax.
by DavidTreitel
Mon Aug 05, 2019 6:19 pm
Forum: International Tax
Topic: Exchange rate and time of exchange for tax
Replies: 3
Views: 4674

Re: Exchange rate and time of exchange for tax

Was this employment income? Business Income? Investment Income? Capital Gain? Where are you domiciled for UK tax purposes? Are you a US citizen, green card holder or resident?
by DavidTreitel
Fri Jul 26, 2019 9:09 pm
Forum: International Tax
Topic: UK tax on INHERITED IRAs
Replies: 1
Views: 3662

Re: UK tax on INHERITED IRAs

Is the accountant a UK accountant or a US accountant or like some of us qualified in both countries? I have met HMRC several times to discuss "lump sums" and HMRCs view is now fairly clear, even if naturally it is not entirely certain if HMRC are accurate. This is a really complex subject and truthf...
by DavidTreitel
Fri Jul 19, 2019 8:53 am
Forum: International Tax
Topic: Self Employed - US taxes living in England
Replies: 1
Views: 3478

Re: Self Employed - US taxes living in England

Most folks would use the IRS Streamlined Foreign Offshore Procedures (SFOP) to catch up: https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states. It would unusual however to owe any tax to the United States because, broadly speaking, rates of tax are ...
by DavidTreitel
Sun Jun 02, 2019 7:32 pm
Forum: Income Tax
Topic: Visitors tax Liability
Replies: 6
Views: 348

Re: Visitors tax Liability

Life is a little more complicated than you say. From a US perspective, as a US person your mother in law will continue to report worldwide income and gains. The US may give credit for UK tax payable. The treaty between the two countries can over-ride domestic UK law on residence if needed. Do not ov...

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