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Where Taxpayers and Advisers Meet

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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: 1042

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: 2648

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: 2214

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: 1846

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: 2214

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: 1651

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: 1455

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: 290

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...
by DavidTreitel
Mon May 27, 2019 2:05 pm
Forum: Income Tax
Topic: Travelling in style
Replies: 4
Views: 366

Re: Travelling in style

The work in the United States will necessitate the filing of a US Federal (and possibly one or more State) income tax return. Whether or not there will be US tax due will be a question of facts and circumstances.
by DavidTreitel
Sat Feb 23, 2019 9:22 am
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: UK tax for house in the USA
Replies: 6
Views: 519

Re: UK tax for house in the USA

From a US perspective, in terms of any future gain on sale your son takes on your cost basis on any future sale of his share of the property. Consequently, he will not get the step up in basis on your death that he would otherwise expect. From a US perspective, this gifting plan might therefore resu...

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