durham_lad

I don’t know, which is why I said I hoped someone would come along with more information. That link you provided is excellent information for the person asking the question. They can now compare their circumstances against the triggers for the exit tax.

Russet

For entering the Interest, dividends and gains from the 1099s on the HMRC return do you need to exchange USD to GBP currency as at the date of each individual payment? or can they be grouped using an average rate for the year?

Just to clarify, In the example for the first year return, it implies that US Income received Jan - Apr of the UK tax year is not reported until the following UK tax year?

Thank you

durham_lad

Yes, the first year HMRC return did not report the US income Jan - Apr until the following year. Once you have chosen this method you must stick with it.

I Google “HMRC exchange rates” then use the average monthly HMRC rate for each payment. I keep a spreadsheet with the payments (US pensions, dividends etc) month by month and using the HMRC exchange rate for the month convert to USD.

https://www.gov.uk/government/public...r-2020-monthly

GOALFIRE

Sorry to dig up an old thread but I'm making a load of notes so I have all the great advise on numerous subjects all on one document so I can reference it in the future!

With respect to tracking your UK income and converting that into USD$ do you use the currency exchange on the day of the payment or is there some official rate the IRS will publish similar to the monthly HMRC one?

mrken30

There are IRS published rates https://www.irs.gov/individuals/inte...exchange-rates .and https://www.fiscal.treasury.gov/repo...e/current.html When I worked for a multi-national company we just used Bank of America mid rates for converting to USD. I think as long as you are consistent, it probably doesn't matter.

durham_lad

I agree.

for my pensions which were a regular monthly income I just used the IRS yearly average which they usually publish by end of January the following year.

cator

Like you, I am confused by the taxation issues about returning to the UK after having worked for a french company for many years and then retired in France. Because I kept my UK house during my retirement and spent more than 91 days in the last 3 years I fail the Overseas and UK tests other than leaving this month to get within the 120 days allowed by the tiers system.

I want to leave after April 6 possibly in the summer so as to have better chance in selling my apartment but to do so, I would have spent more thsn 180 days in the UK etc.

It seems to me that the DTA makes the Statutory Test redundant if it means that there's no extra tax to pay òn the French pension and any share dividends since French tax is supposed to be higher. If the UK consider the retirement as employment, then the tiers system would also work out.

countrygirl33

Hi Durham Lad,

How does the tax treaty work when you have a regular IRA ? When I retired , I had my Franklin Templeton mutual funds 403B transferred to an IRA with Charles Schwab . How does the UK tax system deal with IRAs in USA? Thanks

durham_lad

HMRC treat a regular IRA in the USA similar to a UK SIPP in that it is allowed to grow tax deferred and it will only be subjected to any tax when distributions are made at some future date.

countrygirl33

Thanks Durham Lad

cator

Hi Durham lad,

If HMRC treat the IRA savings like a UK SIPP maybe the same applies for a French Assurance Vie which is the same sort of saving for retirement and tax free if kept for a number of years but I have been told that I'd have to close the AssuranceVie before moving back

durham_lad

I really don’t know anything about tax treaties between the UK and France, I am only interested in our circumstances which is the treaty between the USA and UK where all this is spelled out.

Maybe you could start by reading the equivalent treaty with France

https://www.gov.uk/government/public...e-tax-treaties