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  • "Taxing Goodbyes: The IRS's Take on Expatriate Gifts":  Final Regulations on Tax for Gifts and Bequests from Covered Expatriates

    13th January 2025

    The IRS recently published final regulations under Section 2801 of the Internal Revenue Code. Section 2801 was enacted as part of the Heroes Earnings Assista...

  • Definition of Remittances in the UK

    6th December 2024

    As we transition into a new tax regime for non-domiciled individuals, taxpayers who have previously benefitted from the remittance basis will still be subjec...

  • 12 Key U.S. Year-End Tax Considerations: A "12 Days of Christmas" Guide

    26th November 2024

    2024 has seen unprecedented levels of political change across the world, including the recent US election. Regardless of your political association one thing...

  • Potential Tax Policy Under a Donald Trump Presidency

    7th November 2024

    After a tight race, we now know that Donald Trump will be returning to the White House, becoming just the second president in history, after Grover Cleveland...

  • US Limited Liability Companies and Double Taxation

    2nd September 2024

    Introduction The US is a very popular jurisdiction that attracts foreign investment. For those investors who are tax resident in the UK, choosing the right investment structure is key. A favoured U...

  • The Foreign Grantor Trust: International Families with US Connected Family Members

    11th June 2024

    Introduction More and more families are becoming internationally mobile, with family members spread throughout the world. For educational, professional, and lifestyle reasons, the US has become an ...

  • US Tax Residency: Understanding the Rules, Exceptions, and Tax Implications

    30th April 2024

    Introduction: Understanding the concept of tax residency is crucial for individuals living or earning income in the United States. The determination of tax residency has significant implications on...

  • US Trusts with UK Resident Beneficiaries: A Complex Dilemma

    2nd April 2024

    The Dilemma US family trusts continue to be a popular and powerful estate planning tool in the US, providing various tax benefits as well as non-tax benefits in the form of asset protection and wea...

  • Labour’s proposals for Non Doms and what it means for our US taxpayer clients

    20th March 2024

    There has been a lot in the press and articles written by practitioners about how Labour proposes to modify the tax treatment for individuals resident but no...

  • Giving up Green Card or Passport?

    29th February 2024

    Introduction US citizens and green card holders are subject to US taxation and reporting on a global and annual basis, wherever they are physically resident. Whilst US citizenship to some is a very...

  • Navigating Tax Considerations for Non-Americans Investing in US Real Estate

    5th February 2024

    Introduction Investing in US real estate can be an attractive prospect for Non-Resident Aliens (NRAs) seeking to diversify their investment portfolios or establish a foothold in the American proper...

  • U.K. Personal Tax Filing Deadlines & Why the April 5th Year-end?

    9th January 2024

    Overview Tax filing deadlines are an important aspect of personal finance in the United Kingdom. Understanding these deadlines is crucial for individuals to ensure compliance with tax laws and avoi...

  • Understanding the UK Remittance Basis

    18th December 2023

    Overview Individuals who are UK resident but not domiciled (see Understanding domicile for UK tax purposes ) in the UK have the option to be taxed on either the arising basis or the remittance basi...

  • Understanding Subpart F Income

    20th November 2023

    What is Subpart F Income? ‘Subpart F’ literally refers to a specific area of the internal revenue code (IRC) which addresses the Subpart F regime. Subpart F consists of IRC sections 951 – 965, the ...

  • Understanding domicile for UK tax purposes

    7th November 2023

    When it comes to taxation, understanding individual domicile status is crucial. In the U.K., domicile plays a significant role in determining an individual's tax liabilities. It is a complex concep...

  • IRS Streamlined Filing Procedures

    1st November 2023

    The IRS Streamlined Filing Procedures offer a simplified and streamlined approach for non-compliant taxpayers to catch up on their tax obligations without facing excessive penalties or legal repercussions.

  • What is an FBAR?

    28th October 2023

    FBARs, or Foreign Bank Account Reports, are an essential component of the United States government's efforts to combat tax evasion and money laundering. These reports require U.S. citizens and resi...

  • US Estate Tax

    23rd October 2023

    US citizens and those domiciled in the US are subject to US estate tax on their worldwide assets.

  • Understanding the PFIC Rules

    17th October 2023

    Passive Foreign Investment Companies (PFICs) are a significant aspect of international tax planning for individuals with investments and ownership in foreign investment vehicles.

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