U.S.-UK Tax Planning and Traps to Avoid: Reporting Issues, Tax Treaties, Passive Income, Pass-Through Income
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide tax counsel and 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 provision
- Domicile and residency 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 review 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
Amie Colwell Breslow
Ms. Breslow practices across a broad range of U.S. federal tax matters, including cross-border mergers, acquisitions,... | Read More
Ms. Breslow practices across a broad range of U.S. federal tax matters, including cross-border mergers, acquisitions, spin-offs, and other divisive strategies and restructurings. She has extensive experience working with large multinational companies on managing and executing complex, multi-step reorganizations and divestures, developing workable policies at an industry-wide level in response to global economic policy initiatives and changes in foreign tax and corporate law, and advising clients on token offerings and entity structures. As a former in-house tax counsel and attorney at the Office of Associate Chief Counsel (Corporate), Ms. Breslow blends substantive tax knowledge with an understanding of corporate objectives, and first-hand insights on the guidance and publications process.Close
Jason B. Freeman, J.D., CPA
Founder and Managing Member
Mr. Freeman is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. He represents clients in... | Read More
Mr. Freeman is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. He represents clients in litigation and disputes, with a particular focus on federal and state tax controversies. Mr. Freeman handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements. He serves on the law school faculty at SMU’s Dedman School of Law, where he teaches a course in the law of federal income taxation, and he is a frequent public speaker across the country, presenting and educating on various legal topics.Close
Cannot Attend September 28?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.