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

or call 1-800-926-7926
Program Materials

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


Ashman, Joshua
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

Stuart E. Horwich
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

Moss, Ephraim
Ephraim Moss, Esq.

Co-Founder, Partner
Expat Tax Professionals

Mr. Moss is a U.S. attorney specializing in international tax matters. He has extensive experience in counseling...  |  Read More

Rosenfeld, Jeffrey
Jeffrey M. Rosenfeld, Esq.

Blank Rome

Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax...  |  Read More

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