U.S.-UK Tax Planning and Traps to Avoid: Reporting Issues, Tax Treaties, Passive Income, Pass-Through Income
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
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.
Outline
- 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
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
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
Mr. Colclough is a partner in the firm’s private wealth team. He advises both UK residents and international clients on UK tax, trusts, estate and succession issues with a particular focus on international cross-border matters for non-UK domiciled clients (resident in the UK or elsewhere), offshore trustees and family offices. This includes advising on residence, domicile, the remittance basis of taxation, and developing or refining structures and strategies to preserve wealth and avoid unnecessary tax and succession implications. Mr. Colclough is a member of the Society of Trust and Estate Practitioners (STEP) and has obtained the STEP Diploma and the STEP Advanced Certificate in UK Tax for International Clients and a STEP excellence award. He is named as a key lawyer in the leading legal directory Legal 500, and is ranked in Chambers in the High Net Worth Guide and as a lawyer with foreign expertise in South Africa. Mr. Colclough is included in the top 100 Crypto Advisers and managers curated by Citywealth as highly accredited.
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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
Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and Connecticut). She enjoys learning about her clients’ circumstances and goals, and she works hard to make complex tax concepts more accessible so that clients are empowered to make informed decisions about what matters to them. Because Ms. Konschnik has practised in London for many years, she has significant experience helping clients navigate multiple tax systems. Her primary expertise is in working with owner-managed businesses in a cross-border context. Ms. Konschnik's clients include family-owned and closely-held businesses (and their owners), entrepreneurs, and private equity, real estate and venture capital fund principals. In addition to regular advisory work for her long-term clients, she frequently works with management teams in private equity buyout and roll-over transactions.
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Inga Sviderskiene
Senior Manager, US/UK Private Client
Blick Rothenberg
Ms. Sviderskiene is a Senior Manager at Blick Rothenberg.
| Read MoreMs. Sviderskiene is a Senior Manager at Blick Rothenberg.
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