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Search: Posts Made By: Cook_County
Showing results 1 to 25 of 902
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Forum: USA
Apr 8th 2024, 7:26 pm
Replies: 35
Views: 1,700
Posted By Cook_County

Re: Rishi Sunak held Green Card for 6 years as MP

When I spoke with Boris after shaking his hand in January 2010 (while he was London Mayor) he told me that he know that he had to file lots of US tax returns but could not be bothered. I agree that...
Forum: USA
Apr 5th 2024, 5:47 pm
Replies: 35
Views: 1,700
Posted By Cook_County

Re: Rishi Sunak held Green Card for 6 years as MP

PM Sunak filed US returns each year as a treaty-based non-resident. This is a common strategy. Bizarre for the then Chancellor of the Exchequer - but common among the larger population.
Forum: USA
Apr 4th 2024, 1:52 pm
Replies: 35
Views: 1,700
Posted By Cook_County

Re: Rishi Sunak held Green Card for 6 years as MP

PM Sunak uses Evelyn Partners to prepare his US and UK tax returns. He filed treaty-based non-US resident tax returns each year until he abandoned his green card.
Forum: USA
Mar 24th 2024, 11:43 am
Replies: 20
Views: 1,130
Posted By Cook_County

Re: Inheritance Planning

Your parents idea is a common misunderstanding - but has horrid consequences. It is a GROB, so has no effect on IHT, and results in both UK CGT and US income tax liabilities when the property is...
Forum: USA
Mar 24th 2024, 11:40 am
Replies: 3
Views: 475
Posted By Cook_County

Re: Selling a home in the UK

The estate is a specified foreign financial asset, Distributions from the estate - whether in cash or in specie are reported on Form 3520. Unless your solicitor thinks differently, I'd have estate...
Forum: USA
Mar 21st 2024, 9:05 pm
Replies: 16
Views: 1,319
Posted By Cook_County

Re: SIPP distribution on death

Whether 17(1)(b) can be applied to a US resident has been widely discussed previously in this Forum. Some good folks believe it can, others not. Some lawyers believe that a complete distribution is a...
Forum: USA
Mar 21st 2024, 7:58 pm
Replies: 16
Views: 1,319
Posted By Cook_County

Re: SIPP distribution on death

I am sorry to disappoint you, but there is not a single US qualified tax lawyer or accountant in the UK who believes that Rev Proc 2020-17 applies to UK plans. This is a comment from one of the "Big...
Forum: USA
Feb 25th 2024, 8:34 am
Replies: 4
Views: 554
Posted By Cook_County

Re: Foreign Tax Credit

The rental activity is reported in the US on Schedule E plus Forms 1116 and 8858. All 3 forms are required. Because the US allows mortgage interest as an expense and requires that one claims...
Forum: USA
Feb 23rd 2024, 5:22 pm
Replies: 2
Views: 585
Posted By Cook_County

Re: Inheritance questions...

The distribution from the trust is not an inheritance. You will want to ask the trustees to provide you with what is called a "foreign non grantor trust beneficiary statement" so that you can...
Forum: USA
Jan 28th 2024, 6:10 pm
Replies: 16
Views: 1,897
Posted By Cook_County

Re: Delinquent FBAR/8938's

The DIIRSP is never wise to use because IRS policy is automatically to assess penalties and then have taxpayers go through the appeals process over the next 2 to 3 years. Options available include...
Forum: USA
Jan 28th 2024, 6:03 pm
Replies: 16
Views: 1,897
Posted By Cook_County

Re: Delinquent FBAR/8938's

The statute of limitations NEVER expires for the entire return if Form 8938 is missing or incorrect.
Forum: USA
Jan 20th 2024, 1:10 pm
Replies: 7
Views: 723
Posted By Cook_County

Re: Green card holder outside of country for more than 6 months

Purely from a tax perspective, the absence has no effect. They will want to ensure they file their US income tax returns and FBARs for 2023 on a timely basis.
Forum: USA
Jan 20th 2024, 1:07 pm
Replies: 72
Views: 7,795
Posted By Cook_County

Re: UK State Pension and US tax return

The UK State pension is entered as pension income on Lines 5a and 5b on Form 1040. It is foreign source, so is also entered on Form 1116, which may assist if there are foreign tax credit carryovers...
Forum: USA
Jan 3rd 2024, 4:17 pm
Replies: 19
Views: 1,441
Posted By Cook_County

Re: FBAR Errors

The SDOP is a perfect solution for failing to file accurate US income tax and information returns in the circumstances described. The 5% penalty is tens of thousands of dollars below the statutory...
Forum: USA
Jan 3rd 2024, 3:54 pm
Replies: 19
Views: 1,441
Posted By Cook_County

Re: FBAR Errors

Thanks for catching my small typo. I should have typed:
Most folks would use the official penalty-free IRS Streamlined Domestic Offshore Procedures (SDOP) as the lowest risk and lowest cost way of...
Forum: USA
Jan 3rd 2024, 12:00 pm
Replies: 19
Views: 1,441
Posted By Cook_County

Re: FBAR Errors

Most folks would use the official penalty-free IRS Streamlined Foreign Domestic Procedures (SDOP) as the lowest risk and lowest cost way of catching up....
Forum: USA
Dec 21st 2023, 5:48 pm
Replies: 3
Views: 1,110
Posted By Cook_County

Re: Selling UK home

From a US perspective:

The rental activity is calculated and reported on Schedule E, Form 8858 plus Form 1116.
Any gain on the sale of the residence is exempt from tax if the property was owned...
Forum: USA
Dec 10th 2023, 5:03 pm
Replies: 10
Views: 945
Posted By Cook_County

Re: PFICs (again)

If you ignore the section relating to France, this article is the best written discussion I have ever read on the US taxation of non-US insurance products: French Life Insurance Policies: A U.S....
Forum: USA
Dec 10th 2023, 5:01 pm
Replies: 10
Views: 945
Posted By Cook_County

Re: PFICs (again)

This IRS audit guide may assist: foreign_insurance.pdf (irs.gov) (https://www.irs.gov/pub/irs-mssp/foreign_insurance.pdf)
Forum: USA
Dec 10th 2023, 4:57 pm
Replies: 10
Views: 945
Posted By Cook_County

Re: PFICs (again)

This IRS tool may assist: Are the Life Insurance Proceeds I Received Taxable? | Internal Revenue Service (irs.gov) (https://www.irs.gov/help/ita/are-the-life-insurance-proceeds-i-received-taxable)
Forum: USA
Dec 7th 2023, 6:33 pm
Replies: 10
Views: 945
Posted By Cook_County

Re: PFICs (again)

Whilst you would want/ need a US lawyer to look at this, there is an often persuasive argument that the kind of trust used by insurance bond salespeople in the UK may not meet the US definition of a...
Forum: USA
Nov 2nd 2023, 1:37 pm
Replies: 9
Views: 716
Posted By Cook_County

Re: Treatment of SEIS by the IRS

I would be surprised if the shares are not PFICs. You may want to ask the company if they have the capacity to do any PFIC testing, it is usually the passive asset test that catches EIS holdings.
Forum: USA
Sep 24th 2023, 5:02 pm
Replies: 17
Views: 2,498
Posted By Cook_County

Re: UK bank account and pension in US enquiry

This official IRS publication on the US tax treatment of foreign currency transactions may assist:Character of Exchange Gain or Loss (irs.gov)...
Forum: USA
Sep 8th 2023, 10:53 am
Replies: 6
Views: 1,183
Posted By Cook_County

Re: UK Inheritance

Let's start at the beginning. You are NOT receiving an inheritance. You are receiving a distribution from a foreign non-grantor trust which has a US beneficiary. Assuming the trustees know that you...
Forum: USA
Aug 25th 2023, 3:39 pm
Replies: 9
Views: 752
Posted By Cook_County

Re: Need LA based financial advisor for US/UK move

A living trust is a disaster for a UK resident or domiciliary, even more so if you might move back to California. Dissolving it is the only practical solution unless - like Britney Spears - you to...
Showing results 1 to 25 of 902
 
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