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Dual Citizen moving to the UK

Dual Citizen moving to the UK

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Old Jul 12th 2017, 12:17 pm
  #16  
 
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Default Re: Dual Citizen moving to the UK

Originally Posted by Missl73
With all due respect, ....
With all due respect you sound more than a little patronizing.
.... it's much more complicated than this, ....
NSS
.... residency for tax purposes needs to be determined and that isn't always as clear cut as it sounds in this situation trust me. .....
"Trust me". Seriously? .... see my first comment, above
.... In addition to this it's about all your possible sources of income, not just that which you receive from your employer. Given the OPs situation it sounds likely they may be spending time travelling between the two .....
You're just guessing and basing advice on speculations is likely pointless.

This is a Web forum, and the only thing that makes sense in complex situations like this is to give some general advice and principles as to what is likely and then leave the details to a professional, but my advice above holds - if the OP is living and working in the UK* but being paid by two companies then all his pay will be taxed in the UK, and UK payroll taxes must by paid by the employer. Conversely if he was paid in part in the US and US payroll taxes paid (for which there is no liability) on that part then the OP's employers will create an unholy mess of taxes and would likely leave the OP with a tax liability in the UK.

As a US citizen the OP will still have to complete a US tax return even if he relocates his entire existence, including investments, to the UK.

* If the OP'S work is carried out partly in the UK and partly in the US then the situation may become much more complicated.
Originally Posted by Missl73
Then you will definitely have to complete tax returns in both countries. ...
As he is a dual US/UK citizen who will be working for a substantial part of the year, or longer, in the UK he will have to complete tax returns in each country, full stop!
Originally Posted by BigBgoh
Ok, so professional help is key. ....
It sounds like your employer needs tax advice as much as you do - by trying to pay you on payrolls in two countries they are making what is already a complex situation, massively more so. It is usual under this type of situation for the employer to use one payroll* and then have an inter-company book transfer for the foreign company to reimburse the company in the UK.

* If taxable work is also being performed in the US then there may still be a need to use a US payroll for some of his pay.

Last edited by Pulaski; Jul 12th 2017 at 1:30 pm.
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Old Jul 12th 2017, 12:37 pm
  #17  
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Default Re: Dual Citizen moving to the UK

Originally Posted by Pulaski
With all due respect you sound more than a little patronizing.NSS"Trust me". Seriously? .... see my first comment, above
You're just guessing and basing advice on speculations is likely pointless.

This is a Web forum, and the only thing that makes sense in complex situations like this is to give some general advice and principles as to what is likely and then leave the details to a professional, but my advice above holds - if the OP is living and working in the UK* but being paid by two companies then all his pay will be taxed in the UK, and UK payroll taxes must by paid by the employer. Conversely if he was paid in part in the US and US payroll taxes paid (for which there is no liability) on that part then the OP's employers will create an unholy mess of taxes and would likely leave the OP with a tax liability in the UK.

As a US citizen the OP will still have to complete a US tax return even if he relocates his entire existence, including investments, to the UK.

* If the OP'S work is carried out partly in the UK and partly in the US then the situation may become much more complicated.

As he is a dual US/UK citizen who will be working for a substantial part of the year, or longer, in the UK he will have to complete tax returns in each country, full stop!
I'm not on this forum to be bullied by people like you, I am only trying to help the OP. Your general advice wasn't that helpful and massively over simplified the situation.

If you actually read the OPs later posts he is going to be in a situation where he is on US and UK payroll which is exactly the situation I am in which is why I can comment with some personal knowledge and to your own comment yes makes things much more complicated - I can say trust me I am in that situation myself and it's taken hours and hours of my time working with my accountants to make sure I get it right. My only actual advice was not to go ahead without seeking advice from a professional. I'm going to leave this site because I'm not interested in being spoken to so rudely.
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Old Jul 12th 2017, 1:27 pm
  #18  
 
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Default Re: Dual Citizen moving to the UK

Originally Posted by Missl73
I'm not on this forum to be bullied by people like you, I am only trying to help the OP. Your general advice wasn't that helpful and massively over simplified the situation. ....
That's your opinion, but that doesn't make it a fact, and neither I, nor anyone else has to agree with it. You don't get to come in here and lay down the law.
... If you actually read the OPs later posts he is going to be in a situation where he is on US and UK payroll ....
That is exactly what doesn't make sense in most cases, and should be avoided. Unless the OP is working in both countries, it is as much benefit to the employer as the employee, to compensate the employee through one payroll in one country.
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Old Jul 12th 2017, 1:38 pm
  #19  
 
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
.... Also, anyone know a place to get insurance on a US drivers license? I know Direct Line had said they would insure me, however on a "run of the mill car" which I'm not sure what that means. Any recommendations for exotic cars?
You should start a separate thread for car-related advice, but suffice to say for now, you will only have 12 months to get a UK driving licence, and do not underestimate how hard this may be. I would recommend 5-10 driving lessons no matter how experienced you think you are, because a British road test is about 40 minutes of intense scrutiny of your driving, during which you will have to do most, if not all, of a laundry list of set-piece maneuvers - parallel park, three point turn, reverse round a corner, emergency stop, etc.

I would aim to get started early, soon after you arrive, and plan to take your first test after about four months, which will give you plenty of time to take the test again (the fail rate is about 50%, every time you take the test - so there is a 25% chance you'll fail twice), perhaps two or three times (you have to wait a month between tests). .... And if you take your test in an automatic car your licence will only be valid for driving automatic vehicles.

Last edited by Pulaski; Jul 12th 2017 at 2:15 pm.
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Old Jul 12th 2017, 2:13 pm
  #20  
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
I have been searching a lot of the forums and can't find anything specific to my situation (surprisingly)

I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.

Company A is in the US.
Company B is in the UK.

Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.

Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
I have moved your thread over to our UK Forum for general discussions. Please note the BE Immigration forums are for questions regarding visas and citizenship only. Thanks.
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Old Jul 12th 2017, 2:44 pm
  #21  
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
I have been searching a lot of the forums and can't find anything specific to my situation (surprisingly)

I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.

Company A is in the US.
Company B is in the UK.

Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.

Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
Hi there, give the Insurance broker Keith Michaels a call as they deal with expats and other nationals coming to the UK
https://www.keithmichaels.co.uk/spec...car-insurance/
Good Luck
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Old Jul 12th 2017, 5:27 pm
  #22  
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Default Re: Dual Citizen moving to the UK

Originally Posted by scot47
Most countries have Double Taxation Agreements - designed to avoid the need to pay tax in two jurisdictions. You need a competent accountant.
It is important to grasp the concept that US/UK double taxation agreement relates to relief that takes into account tax actually paid in the "other" country. As contrasted with relief of potentially taxable income. You will be aware of course that the US assesses for tax the worldwide income of US citizens no matter where in the world they live, but being assessed for tax does not always mean owing any tax.

You will be employed and paid and taxed for working and living in the UK. You need professional advice as to whether money paid in the US is taxed or tax free in the UK. That depends on what the money is "payment for". Is it for example payment for services currently being rendered? Or is it a retainer to remain on company books in the US with a view to returning there one day in the distant future? Is it a loan that will be forgiven if you fulfill certain conditions but must be repaid if you don't? The difference may or may not be crucial, only a professional American tax adviser with double taxation agreement experience can advise.
It may be that the tax you pay in the UK on your UK income provides double taxation relief in the US on your worldwide income such that you end up owing no tax at all in the USA! Lots of Yanks have arranged things that way.
The bottom line is
1. It is all very complicated you need professional advice.
2. If you potentially have large incomes in both US and UK then the total amount of tax owed may vary by a huge sum depending on how you and your employer arranges your affairs.
There are no easy answers.
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Old Jul 14th 2017, 8:30 pm
  #23  
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Default Re: Dual Citizen moving to the UK

For 6 years I was living in the USA where most of my salary was paid into my US bank, and part was paid into my UK bank from which my pension and NI contributions were taken.

I was required to keep a diary of time spent in the UK, both business and personal.

The company provided specialist tax accountants to handle my taxes. It's complicated.
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