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
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.
- U.S.-U.K Tax Treaty overview and dual tax mitigation provisions
- Domicile rules
- Passive and unearned income treatment
- U.S. tax reporting requirements of UK-sourced investments
- 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
Joshua Ashman, CPA
Expat Tax Professionals
Mr. Ashman is an international tax accountant. He counsels Americans abroad regarding filing their U.S. taxes. He... | Read More
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.Close
Stuart E. Horwich
D&H Global Tax Group
Mr. Horwich is a US lawyer who has spent his career specializing in international tax issues. He has worked for the... | Read More
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.Close
Ephraim Moss, Esq.
Expat Tax Professionals
Mr. Moss is a U.S. attorney specializing in international tax matters. He has extensive experience in counseling... | Read More
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.Close
Jeffrey M. Rosenfeld, Esq.
Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax... | Read More
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.Close
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CPE On-DemandSee NASBA details.