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

Analyzing Tax Treaties to Minimize Tax: Impact of Brexit, Passive Income, and Pass-Through Income

Note: CLE credit is not offered on this program

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

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Conducted on Thursday, August 27, 2020

Recorded event now available

or call 1-800-926-7926

This course 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 UK 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 UK residency and expatriation rules, and detail the effect of Brexit on treaty benefits.


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, UK 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 UK rules governing residence and domicile. UK 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 UK will need to understand the domicile rules to avoid expensive tax and penalties.

Another critical planning element is avoiding dual taxation on income and gains. The U.S. and the UK 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.-UK tax planning include the treatment of passive income, tax considerations of cross-border pension ownership, and most recently, the departure of the UK from the European Union (EU). Companies relying on treaty benefits where a UK resident was also considered a resident of an EU member state may need to look at the treaty anew. Hovering over all these concerns is 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.-UK cross-border tax planning and reporting issues.



  1. The U.S.-UK income 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
  6. The impact of Brexit on treaty 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 the U.S.-UK income tax treaty
  • How treaty benefits may be affected by Brexit
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of UK-sourced investments


McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.

Culhane Meadows Haughian & Walsh

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  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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