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Where Taxpayers and Advisers Meet

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by DavidTreitel
Sat Dec 15, 2018 1:50 pm
Forum: International Tax
Topic: Completion of IRS form 8833
Replies: 1
Views: 671

Re: Completion of IRS form 8833

Jane - just a helpful hint. You doubtless have a PTIN (so that you can sign as preparer to avoid the IRS preparer penalty). You are hopefully also qualified in the States (as an EA or CPA). From a practical perspective, however, as you are located in the UK you will want to double check with your PI...
by DavidTreitel
Thu Nov 29, 2018 1:45 pm
Forum: International Tax
Topic: US withholding tax on dividends
Replies: 3
Views: 1499

Re: US withholding tax on dividends

The normal withholding tax rate on FDAP income is 30%, reduced under the UK treaty to 15%: https://www.irs.gov/individuals/international-taxpayers/fixed-determinable-annual-periodical-fdap-income Sounds likely the payer has applied the wrong treaty rate. To recover this, the individual will need to ...
by DavidTreitel
Mon Nov 19, 2018 9:49 am
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: Gift/Inheritance Tax Non Domiciled Person
Replies: 13
Views: 1633

Re: Gift/Inheritance Tax Non Domiciled Person

A gift of real property in the United States can give rise to a US gift tax liability.
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: 309

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: 419

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: 799

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: 1377

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: 1784

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: 1059

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: 807

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...

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