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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

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Thursday, November 7, 2024 (in 5 days)

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel and advisers with a practical guide to issues that arise in relation to 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, give an overview of UK residence and domicile rules, and discuss treaty benefits.

Description

The U.S. and UK have significant economic and social ties resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges stemming from the interpretation and enforcement of U.S. and UK tax rules to avoid adverse tax liability from either country.

Among the most critical planning challenges for cross-border activities is reconciling the U.S. and UK 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 a presence in the U.S. and the UK 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. has detailed domestic foreign tax credit rules, along with a comprehensive tax treaty with the U.K. that together address 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 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.-UK cross-border tax planning and reporting issues.

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Outline

  1. The U.S.-UK income tax treaty overview and dual tax mitigation provision
  2. Domicile and residency 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 review these and other important topics:

  • What are the applicable domestic and treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities and trusts?
  • Limitation of benefits clauses and provisions in the U.S.-UK income tax treaty
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of UK-sourced investments

Faculty

Colclough, Jonathan
Jonathan Colclough

Partner
BDB Pitmans

Mr. Colclough is a partner in the firm’s private wealth team. He advises both UK residents and international...  |  Read More

Hughes, Annie
Annie Hughes

Senior Tax Manager
Blick Rothenberg

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 |  Read More
Konschnik, Kristin
Kristin E. Konschnik

Attorney
MK Law London

Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and...  |  Read More

Attend on November 7

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Cannot Attend November 7?

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.

To find out which recorded format will provide the best CLE option, select your state:

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