UK US Tax provides tax planning advice for its clients, including ways for U.S. citizens to minimize their worldwide tax liabilities. For non U.S. persons, we can advise regarding pre-immigration planning or with respect to investments in U.S. assets. Often times this involves U.S. real estate and inheritance and real estate issues.
U.S. citizens living abroad are confronted with a number of different issues, including maximizing their ability to credit foreign taxes, avoiding adverse implications associated with investment in foreign companies, and making various elections required under the Internal Revenue Code regarding corporate holdings and activities. These issues are often exacerbated when the American citizen has a non U.S. citizen spouse.
For non Americans, the U.S. tax system is complex and formidable. Often, however, it is possible to take advantage of a number of elective provisions, such as the “check-the-box” rules and the “net election” rules to reduce, if not eliminate, U.S. tax on investments made by non-U.S. persons. Nowhere is making elections more crucial than in the acquisition of U.S. real estate (whether directly or through holding vehicles). UK US Tax has been assisting non U.S. persons in tax efficient structuring for their U.S. source investments, including minimizing the effect of the Foreign Investment in Real Property Tax Act (FIRPTA) and avoiding pitfalls that potentially can cause a U.S. investment to be taxed at three different levels in the United States.
For non U.S. individuals moving to the United States, UK US Tax has devised a number of techniques to minimize U.S. taxes. These include not only structures for the ultra high net worth individuals, such as using insurance wrappers and deferred variable annuities, but also practical solutions that can be implemented at lower costs for basic issues. Likewise, a move to the United States may involve the need to sell a family residence which may not be possible prior to arrival in the United States. We have been able to plan appropriately to allow clients to obtain a fair market value for the U.K. family home without triggering a tax or stamp duty charge; thus allowing for an orderly sale at a time that suits the taxpayer moving to the United States rather than being accelerated to avoid U.S. tax costs that would otherwise apply.
Reducing the U.S. tax burden is not, however, the only issue confronting U.S. and non U.S. taxpayers. Indeed, taxpayers must take into account the taxes imposed by a number of jurisdictions worldwide to arrive at the most effective global solution to their tax problems. UK US Tax coordinates US advice with professional advice in a number of other European, North American and Asian countries in which the UK US Tax Services partners have worked over the years. UK US partners are regular speakers at various training seminars including FACTA and host an annual tax conference with 20 tax professionals from jurisdictions throughout the world, ensuring that non U.S. advice is readily available in a multitude of different jurisdictions.