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Where Taxpayers and Advisers Meet

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by DavidTreitel
Sun Dec 29, 2019 10:52 am
Forum: International Tax
Topic: Foreign income internship
Replies: 10
Views: 1526

Re: Foreign income internship

Did you file a Form 1040NR for 2018?
by DavidTreitel
Sun Dec 29, 2019 9:50 am
Forum: International Tax
Topic: Foreign income internship
Replies: 10
Views: 1526

Re: Foreign income internship

Based on the data provided it is almost certain you had a J-1 or F-1 visa and as a consequence were not US resident. You would have file Form 1040NR for 2018 reporting the numbers from your W-2. Whatever tax was due on that US return is creditable in the UK.
by DavidTreitel
Sat Dec 14, 2019 4:09 pm
Forum: Capital Gains Tax, CGT
Topic: CGT Eligibility Test on Sale of Property
Replies: 3
Views: 6631

Re: CGT Eligibility Test on Sale of Property

Paul - You and your wife had US green cards. Were these abandoned? Were you subject to the expatriation tax? If so, did you file Forms 8854? These issues are common and the kind of US tax question we help with professionally every day. Feel free to contact me if this is not yet resolved. David Treit...
by DavidTreitel
Sat Dec 14, 2019 11:56 am
Forum: International Tax
Topic: Inherited IRA distribution and HMRC reporting
Replies: 2
Views: 765

Re: Inherited IRA distribution and HMRC reporting

The RMD is considered UK taxable income. The 30% withholding is simply that. The UK has the primary right to charge tax. The United States gives credit for UK tax paid under Article 24 of the US/UK tax treaty. You will therefore want to make sure you have paid the UK tax for both 2018-19 and 2019-20...
by DavidTreitel
Sat Nov 30, 2019 9:13 am
Forum: Savings & Investments, Pensions & Retirement
Topic: Taxation of gains from USA shares
Replies: 2
Views: 1824

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: 755

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: 6543

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: 6477

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: 5695

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: 11634

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...

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