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Where Taxpayers and Advisers Meet

Disregarded income in US

Tax mole
Posts:1
Joined:Mon Apr 25, 2022 4:07 pm
Disregarded income in US

Postby Tax mole » Mon Apr 25, 2022 4:17 pm

I've got a scenario which has sent me round in circles.

UK consulting company, wholly owned by a UK resident, US citizen. Income is wholly from UK/EU.

Very happy with UK taxation however in US, the individual is taxed on the basis that the company is a disregarded entity, essentially an extension of the individual taxpayer. The company wrapper is ignored completely. Where I'm getting stuck is that CT has been paid in the UK and US tax is due on the same profit. I'm trying to work out where double tax relief can be claimed.

Any thoughts welcome.

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