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
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 U.S.-UK income 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 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
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
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.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