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Where Taxpayers and Advisers Meet

Search found 213 matches

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by DavidTreitel
Mon Oct 29, 2018 7:21 pm
Forum: Income Tax
Topic: Does a cost basis adjustment in foreign shares create taxable income?
Replies: 1
Views: 246

Re: Does a cost basis adjustment in foreign shares create taxable income?

Sounds from the published legal opinion that you are recognising gain rather than income: https://investors.hpe.com/~/media/Files/H/HP-Enterprise-IR/documents/seattle-6045b-statement-26092017.pdf You'd want to treaty resource the gain on the 2017 US return (on a treaty resourced Form 1116) if there ...
by DavidTreitel
Fri Oct 26, 2018 9:33 am
Forum: Income Tax
Topic: Seconded Overseas UK to China
Replies: 2
Views: 334

Re: Seconded Overseas UK to China

Doubtless some tax is due to China and/or Thailand on Chinese/Thai source income. You can claim double tax relief for that tax in the UK. Hopefully your employer is helping with preparing and filing of those tax returns.
by DavidTreitel
Wed Oct 17, 2018 12:16 pm
Forum: International Tax
Topic: Taxation of inherited deferred annuity from the USA
Replies: 1
Views: 683

Re: Taxation of inherited deferred annuity from the USA

As a US citizen you remain subject to US tax on worldwide income and gains and may need to file information returns - including (but not limited to) an FBAR. Relief for double taxation is generally provided under the resourcing Article of the US/UK tax treaty (Article 24) which allows you to claim r...
by DavidTreitel
Tue Oct 16, 2018 9:36 am
Forum: PAYE and Payroll Taxes, National Insurance, NICs
Topic: income from rental
Replies: 3
Views: 1225

Re: income from rental

The son in the United States needs to be registered in the UK for the non-resident landlord scheme and file a UK tax return. In the United States he is similarly required to declare his share of the income and claim expenses (including depreciation). Hopefully he is recording his share of money you ...
by DavidTreitel
Sat Oct 13, 2018 10:54 am
Forum: International Tax
Topic: UK-US S-Corp (Opaque) double taxation (K-1)
Replies: 1
Views: 1020

Re: UK-US S-Corp (Opaque) double taxation (K-1)

An S-Corp is an extremely unusual entity choice for a UK resident. From what you describe, the corporation is UK resident (because it is managed and controlled in the UK) and therefore subject to UK corporation tax on its profits. Hopefully it has registered with HMRC and is paying UK corporation ta...
by DavidTreitel
Mon Sep 03, 2018 7:49 pm
Forum: International Tax
Topic: Tax on Early US Social Security Pension
Replies: 2
Views: 949

Re: Tax on Early US Social Security Pension

As your wife is a US person she is doubtless filing an annual US tax return and FBAR. She'll find if she elects to use the US/UK tax treaty that US social security pension income is completely exempt from US tax. It is - in any event - UK taxable to a UK resident.
by DavidTreitel
Thu Aug 23, 2018 2:17 pm
Forum: International Tax
Topic: USA SEP-IRA lump sum distribution to UK?
Replies: 2
Views: 675

Re: USA SEP-IRA lump sum distribution to UK?

On taking a lump sum distribution the income will be subject to United States tax at US graduated rates plus the 10% penalty. It would be wise to ask the payer to withhold roughly the right amount rather than zero. You will still need to file a US tax return in the following year to calculate the fi...
by DavidTreitel
Wed Jul 11, 2018 4:17 pm
Forum: International Tax
Topic: Belgium pension plan - reportable??
Replies: 0
Views: 552

Belgium pension plan - reportable??

Client is UK resident and domiciled. He casually mentions he has a former employer's pension plan in Belgium worth £100,000 (in his 20s he lived and worked in Belgium for a few years). He is now old enough to cash it in; but has not done so. Is income within the plan reportable to HMRC. Should clien...
by DavidTreitel
Fri Jun 29, 2018 5:06 pm
Forum: Income Tax
Topic: Possible £114k tax bill from income earned abroad as now UK tax resident.
Replies: 4
Views: 638

Re: Possible £114k tax bill from income earned abroad as now UK tax resident.

The company is UK resident as it is managed & controlled in the UK (it was imported to the UK when you became UK resident).
by DavidTreitel
Fri Jun 08, 2018 8:46 pm
Forum: International Tax
Topic: Inheritance from Thailand
Replies: 3
Views: 963

Re: Inheritance from Thailand

The US resident donee will file IRS Form 3520.

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