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Where Taxpayers and Advisers Meet

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by DavidTreitel
Sat Nov 30, 2019 9:13 am
Forum: Savings & Investments, Pensions & Retirement
Topic: Taxation of gains from USA shares
Replies: 2
Views: 1360

Re: Taxation of gains from USA shares

But cost and proceeds are converted to Pounds at spot rates for the dates of purchase & sale. This can result in a gain in Pounds and a loss in Dollars or vice versa.
by DavidTreitel
Mon Nov 18, 2019 10:12 am
Forum: International Tax
Topic: Whether to report foreign capital gains if less than HMRC capital gains allowance?
Replies: 1
Views: 544

Re: Whether to report foreign capital gains if less than HMRC capital gains allowance?

Are you certain these are not Offshore Income Gains, rather than capital gains?
by DavidTreitel
Tue Oct 29, 2019 9:23 am
Forum: Income Tax
Topic: tax for non resident
Replies: 2
Views: 5587

Re: tax for non resident

You will need to file a US return for 2018 and 2019 - the kind of income and assets to be reported will depend on your US visa category.
by DavidTreitel
Tue Oct 01, 2019 7:02 pm
Forum: Income Tax
Topic: taxation of income from a USA IRA distribution
Replies: 3
Views: 5621

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: 5038

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: 10863

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: 12682

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: 11550

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: 11427

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: 11550

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?

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