U.S.-U.K. Dual Taxation Pitfalls: Reporting Issues and Planning Opportunities for U.S. Taxpayers

Navigating Tax Treaties to Minimize Tax on Passive Income and Pass-Through Income

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, June 13, 2017
Recorded event now available

This webinar will provide tax advisers with a thorough and practical guide into the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in the United Kingdom, as well as U.K. citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law and treaty provisions designed to avoid or mitigate dual taxation, describe U.K. residency and expatriation rules, and detail the U.S. reporting and payment obligations specific to passive income as well as U.K. trade or business activity.


The economic and social ties between the United States and the United Kingdom are historically close and long-standing. The demographic similarities between the two countries contribute to the United Kingdom being one of the top trading partners of the United States, as well as the constant flow of citizens migrating between the two countries. Given these circumstances, U.K. citizens residing in the U.S. can frequently get caught up in both countries’ income tax systems, and vice versa.

Among the planning challenges for cross-border activities is reconciling the U.S. and U.K. rules governing residence and domicile. U.K. domicile rules are complex, and even inadvertent failure to meet filing obligations due to a misapplication of domicile rules can be costly. U.S. tax advisers serving clients with presence both in the U.S. and the U.K. will need to understand the domicile rules to avoid costly tax and penalties.

Another critical planning element is avoiding dual taxation on income and gains. The U.S. and the U.K. have a comprehensive tax treaty system that addresses most dual taxation concerns but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill—or maybe two.

Other areas of concern in U.S.-U.K. tax planning include treatment of passive income and tax considerations of cross-border pension ownership, contributions and withdrawals. Hovering over all these concerns are the extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations.

Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-U.K. cross-border tax planning and reporting issues.


  1. U.S.-U.K Tax Treaty overview and dual tax mitigation provisions
  2. Domicile rules
  3. Passive and unearned income treatment
  4. U.S. tax reporting requirements of UK-sourced investments
  5. Limitation of benefit provisions


The panel will discuss these and other important topics:

  • What are the tax treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities?
  • Limitation of benefits clauses and provisions in U.S.-U.K. Income Tax Treaty
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of U.K.-sourced investments


Learning Objectives

After completing this course, you will be able to:

  • Recognize U.S. tax reporting requirements for U.S. taxpayers residing in the U.K.
  • Establish the domicile of the taxpayer and whether tax treaty benefits are available based upon the determined domicile.
  • Distinguish among the various tests used to determine whether a taxpayer is eligible for tax treaty benefits.
  • Identify opportunities to mitigate dual taxation.
  • Identify the limitations of benefits in the U.S.-U.K. tax treaty.


Joshua Ashman, CPA, Partner
Expat Tax Professionals, New York

Mr. Ashman is an international tax accountant. He counsels Americans abroad regarding filing their U.S. taxes. He specializes in expat-specific issues and complicated tax matters. He previously held a senior management position in the international tax practice of PwC.

Stuart E. Horwich, Partner
D&H Global Tax Group, London

Mr. Horwich is a US lawyer who has spent his career specializing in international tax issues. He has worked for the Department of Justice, the SEC, and he opened the London law office for a US law firm. His client base includes banks, multinational companies and privately held businesses operating in the United States and abroad. As an expatriate himself, he fully understands the US and many foreign tax issues associated with living abroad. In addition, he assists US citizens living in the UK and Europe to minimize their overall worldwide tax liability.

Ephraim Moss, Esq., Partner
Expat Tax Professionals, New York

Mr. Moss is a U.S. attorney specializing in international tax matters. He has extensive experience in counseling clients on matters such as cross-border tax structures, tax return treaty positions, expatriation matters and disclosure of foreign financial accounts. In recent years, he has focused his practice on assisting delinquent taxpayers utilize the various IRS disclosure programs and regularly represents client before the IRS. Prior to co-founding Expat Tax Professionals LLC, he held a managerial position in the international tax practice of Ernst & Young.

Jeffrey M. Rosenfeld, Esq.
Blank Rome, Philadelphia

Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax matters including domestic and international tax matters, state and local tax planning, tax-efficient structuring of domestic and international mergers, acquisitions, divestitures, reorganizations, spin-offs, redemptions and liquidations, formation, operation and acquisition of Subchapter S Corporations, partnerships and limited liability companies. He counsels clients regarding undeclared foreign bank accounts, including “FBAR” reporting obligations.

EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


CPE On-Demand

Includes video streaming of full program plus handouts (available within a week of the live webinar).

Strafford is a NASBA-approved CPE provider for On-Demand webinars.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: Printing and reviewing Program Outlines and materials.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: QAS Self-Study.
  • Prerequisite: 

    Three years+ business and international tax experience at a mid-level within an organization with specific knowledge and understanding of tax treaties, foreign financial assets, FATCA and FBAR tax reporting requirements, dual taxation, passive income, and foreign trade and business activity; familiarity with limitation of benefits clauses in income tax treaties and rules governing residence and domicile.

On-Demand Webinar & CPE Processing $182.00

Recorded Event

Includes full event recording plus handouts.

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $147.00

How does this work?

Recorded Audio Download (MP3) $147.00

How does this work?


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IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

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Program Materials

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Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

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EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

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Customer Reviews

I liked the concentration on specific issues and examples.

Edita Rimalovsky

Komisar Brady & Co.

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

Larry Bruck

WISS & Company

I purchased the conference a few minutes after it began and the customer service rep was very helpful and got me signed up and logged into the conference very quickly.

Joanna Johnston

Savas Greene & Company

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

Matt Bristow

Cover & Rossiter

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