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

A live 110-minute CPE webinar with interactive Q&A


Tuesday, June 13, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, May 26, 2017


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.

Description

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.

Outline

  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

Benefits

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 owning U.K.-based retirement schemes and pension accounts
  • Identify the differences in tax treatment of HCE and non-HCE plans

  • Recognize tax deferral provisions in relevant tax treaties and planning opportunities
  • Determine whether the PFIC rules apply to a foreign retirement account

  • Select which IRS forms are necessary to fulfill obligations to report foreign financial assets and interests

Faculty

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 worked at PricewaterhouseCoopers (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.
Expat Tax Professionals, New York

Mr. Moss is an attorney specializing in international taxation. He began his career at Ernst & Young and is an expert on income tax treaties, avoiding double taxation, tax compliance, and IRS disclosure.

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.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $97.00

Includes Early Discount Savings of $50.00 (through 05/26/17)

Live Webinar & CPE Processing $132.00

Includes Live Webinar Early Discount Savings of $50.00 (through 05/26/17)


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign information reporting requirements, including FATCA and FinCEN Form 114; familiarity with foreign income sourcing rules and tax treaty provisions.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

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 or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign information reporting requirements, including FATCA and FinCEN Form 114; familiarity with foreign income sourcing rules and tax treaty provisions.

On-Demand Webinar & CPE Processing $132.00

Includes CPE On-Demand Early Discount Savings of $50.00 (through 05/26/17)


Recorded Event

Includes full event recording plus handouts (available after live webinar).

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

Recorded Webinar Download $97.00
Available 48 hours after the live event

Includes Early Discount Savings of $50.00 (through 05/26/17)

How does this work?

Recorded Audio Download (MP3) $97.00
Available 24 hours after the live event

Includes Early Discount Savings of $50.00 (through 05/26/17)

How does this work?

DVD (Slide Presentation with Audio) $97.00 plus $9.45 S&H
Available ten business days after the live event

Includes Early Discount Savings of $50.00 (through 05/26/17)

How does this work?


Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $144.00

Includes Special Savings of $150.00 (through 05/26/17)

Live Webinar & Audio Download $144.00

Includes Special Savings of $150.00 (through 05/26/17)

Live Webinar & DVD $144.00 plus $9.45 S&H

Includes Special Savings of $150.00 (through 05/26/17)


NASBA CPE Sponsor

National Registry of CPE Sponsors

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

IRS Approved Provider

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

Early Registration
Discount Deadline
May 26, 2017
(about 2 hours)

or call 1-800-926-7926

Can't Attend the Live Program?

CPE Credit

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.

or call 1-800-926-7926

EA Credit

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

or call 1-800-926-7926

Customer Reviews

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

Larry Bruck

WISS & Company

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

The conference was technical, informative and presented at a good pace.

Krystal Ching

KMH

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

or call 1-800-926-7926

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