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-   -   UK-based investments for USA tax resident? (https://britishexpats.com/forum/usa-57/uk-based-investments-usa-tax-resident-889935/)

mrken30 Aug 27th 2017 5:29 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by Pulaski (Post 12325341)
But most US banks that offer non-USD accounts park the account in one of their overseas branches, often in the Cayman Islands, but sometimes locally for the currency - I think Citibank sterling accounts were (are?) held in London.

That is true, the USD account I had in the UK was held in NY. However I could only access/manage the account from the UK arm of Citibank. Also I am not able to do electronic transfers from that account to another US account.

ilikeitlikethat Aug 27th 2017 5:30 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by torriano (Post 12149078)
Interested in (non-binding!) advice from you guys.

I'm a UK citizen, but resident in US for tax purposes, and plan to be for a few years to come at least.

Please elaborate, now, when you say 'for tax purposes' - is this beacuase you live and work in America?
Or..
Something else.

uk_grenada Aug 27th 2017 6:42 pm

Re: UK-based investments for USA tax resident?
 
Actually - just to throw a new spanner in the machine, a lot of offshore investing is going on via hong kong. A friend is a forensic accountant with a big interest in being a liquidator for some smaller jurisdictions. A few months back he told me that because of us and eu reporting agreements with many countries, the swiss and caribbean 'anonymous' account holders were moving investment management to be based in hong kong - physical assets in hand, where their money could properly disappear as the chinese regulated banks tell other countries they wont report anything to them, including the likes of HSBC [there only.]... Anyone able to say this isnt the case? He was clear that to do it requires a trip there, you cant open accounts there or move money electronically without reporting on the way.

Pulaski Aug 27th 2017 6:56 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by uk_grenada (Post 12325479)
Actually - just to throw a new spanner in the machine, a lot of offshore investing is going on via hong kong. A friend is a forensic accountant with a big interest in being a liquidator for some smaller jurisdictions. A few months back he told me that because of us and eu reporting agreements with many countries, the swiss and caribbean 'anonymous' account holders were moving investment management to be based in hong kong - physical assets in hand, where their money could properly disappear as the chinese regulated banks tell other countries they wont report anything to them, including the likes of HSBC [there only.]... Anyone able to say this isnt the case? He was clear that to do it requires a trip there, you cant open accounts there or move money electronically without reporting on the way.

In order to stand any chance whatsoever of getting beyond the reach of Uncle Sam you would need a bank that has absolutely zero US presence, otherwise Uncle Sam will grab the US branch by the short-and-curlies and yank until the pain is unbearable.

Back in the 1990's Uncle Sam decided that they needed some information from the Bank of Nova Scotia (BNS). After several months of a stand-off, with BNS declaring that they were not a US bank and that the information related to a customer in a third country - Bermuda IIRC, Uncle Sam slapped a $1million/day fine on BNS, .... which BNS decided they would ignore.

After somewhere around eight months, by which time the fine was substantially in excess of $200million, BNS realized that Uncle Sam was entirely serious, so they coughed up the information despite the secrecy and privacy laws in the country where the account was held.

uk_grenada Aug 27th 2017 7:02 pm

Re: UK-based investments for USA tax resident?
 
Fine words, now show me an example of the Chinese not giving a flying XXXX what the Americans think given the level of Chinese investment involved. This is one of my accountant friends major issues that if you got money in Hong Kong banks there was no way you can get the information about it from anywhere. Effectively the new gnomes have Chinese eyes.

Pulaski Aug 27th 2017 7:13 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by uk_grenada (Post 12325485)
Fine words, now show me an example of the Chinese not giving a flying XXXX what the Americans think given the level of Chinese investment involved. This is one of my accountant friends major issues that if you got money in Hong Kong banks there was no way you can get the information about it from anywhere. Effectively the new gnomes have Chinese eyes.

You're looking at it from the wrong end - it doesn't matter what the home jurisdiction of the bank thinks. ..... Which was why I specifically mentioned a bank with no connections to the US, because Uncle Sam will seize and close down your US operation if you fail to comply. I suspect that BNS was warned that the fine was reaching the sort of size where Uncle Sam was preparing to seized BNS's US operations to recover the fine. That is more or less what happened to Wegelin & Co, the Swiss bank which is now defunct, killed off by Uncle Sam.

There was an example, but I am struggling to remember the bank and the details - perhaps HSBC, and 15-20 years ago, moved money, on the instruction of a customer, from New York to Hong Kong. Somebody sued in the US to have the money returned, and despite the money being outside the US, and in a bank not headquartered in the US, and that the Hong Kong bank is a separate legal entity, not a branch, for some odd reason, one that I cannot explain, the bank capitulated and returned the money to the US. ..... I can't help but wonder if the customer had any redress for the loss of their money against the bank in Hong Kong over which the US had no jurisdiction. :unsure:

ilikeitlikethat Aug 27th 2017 7:20 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by uk_grenada (Post 12325485)
Fine words, now show me an example of the Chinese not giving a flying XXXX what the Americans think given the level of Chinese investment involved. This is one of my accountant friends major issues that if you got money in Hong Kong banks there was no way you can get the information about it from anywhere. Effectively the new gnomes have Chinese eyes.

PRC take this revenue and launder it in countries like North Korea and that's how North Korea can afford to arm themselves to the teeth.

Let's just keep things simple.
UK citizen in America with UK money sitting in a 0% interest account.

The only problem is, the UK citizen isn't earning any interest on their capital. However, since OP is in the US, why doesn't OP register an LTD in Britain, file annual returns, and then open up and have the LTD start a holding company of an offshore LLC where they live in America and make it a US investment from Britain?
That way they'd get to save their money in a US savings account and report no profit to be taxed on in the UK for corporation tax since there would be no profit to the LTD after founding the LLC which is investing into a savings account. Your UK LTD should become an MNC but, could be something to think about to get your money around for growth, that way, Uncle Sam should see this as a domestic tax issue and the LTD in Britain won't report a profit.

Unless OP is just a tax exile from the UK, in which case, OP owes the UK taxes so would be liable to letters asking OP to pay.

Pulaski Aug 27th 2017 7:30 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by ilikeitlikethat (Post 12325493)
PRC take this revenue and launder it in countries like North Korea and that's how North Korea can afford to arm themselves to the teeth.

Let's just keep things simple.
UK citizen in America with UK money sitting in a 0% interest account.

The only problem is, the UK citizen isn't earning any interest on their capital.

Let's no_ complicate things with offshore and tax avoidance.

However, since OP is in the US, why doesn't OP register an LTD in Britain, file annual returns, and then open up and have the LTD start a holding company of an offshore LLC where they live in America and make it a US investment from Britain?
That way they'd get to save their money in a US savings account and report no profit to be taxed on in the UK for corporation tax since there would be no profit to the LTD after founding the LLC which is investing into a savings account. Your UK LTD should become an MNC but, could be something to think about to get your money around for growth, that way, Uncle Sam should see this as a domestic tax issue and the LTD in Britain won't report a profit.

Unless OP is just a tax exile from the UK, in which case, OP owes the UK taxes so would be liable to letters asking OP to pay.

I am unclear whether you omitted a "t" or a "w", not that it makes much difference to my opinion.

:popcorn:

ian-mstm Aug 27th 2017 7:31 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by ilikeitlikethat (Post 12325451)
I can understand not wanting a stagnate 0% interest bank account in any economy let alone the one of late.

FIFY. No charge!

Ian

ilikeitlikethat Aug 27th 2017 7:34 pm

Re: UK-based investments for USA tax resident?
 
much obliged :)

ilikeitlikethat Aug 27th 2017 7:49 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by Pulaski (Post 12325497)
I am unclear whether you omitted a "t" or a "w", not that it makes much difference to my opinion.

:popcorn:

The whole line was omitted in a draft after the quoted one because I realised the line was redundant since things were already more complicated than they need be, however, having an offshore in PRC (China) is a lot more complicated than things need to be in an already interesting situation.
It was in response to @uk_grenada

Pulaski Aug 27th 2017 8:02 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by ilikeitlikethat (Post 12325493)
PRC take this revenue and launder it in countries like North Korea ....

Obviously it stands to reason that money laundered through North Korea is squeaky clean. :rolleyes:

ilikeitlikethat Aug 27th 2017 9:46 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by Pulaski (Post 12325515)
Obviously it stands to reason that money laundered through North Korea is squeaky clean. :rolleyes:

I'm not touching that with a 10 ft barge poll.
I'm not having Hong Kong PRC controlled tax avoidance.

warren505 Sep 17th 2017 3:38 pm

Re: UK-based investments for USA tax resident?
 
Wow! Complicated stuff.
Can we get back to the OP and me with the same problem. Living and paying tax in USA but have inherentance money in UK at 0% and U.K. Banks and investment firms won't let us invest in UK interest bearing accounts . Need to do until exchange rate improves or our life goals change.
How can I invest GBP in something legal without paying crazy USA taxes? Or taxes in both?
Tks Warren

uk_grenada Sep 17th 2017 3:50 pm

Re: UK-based investments for USA tax resident?
 

Originally Posted by ilikeitlikethat (Post 12325493)
PRC take this revenue and launder it in countries like North Korea and that's how North Korea can afford to arm themselves to the teeth.

Let's just keep things simple.
UK citizen in America with UK money sitting in a 0% interest account.

The only problem is, the UK citizen isn't earning any interest on their capital. However, since OP is in the US, why doesn't OP register an LTD in Britain, file annual returns, and then open up and have the LTD start a holding company of an offshore LLC where they live in America and make it a US investment from Britain?
That way they'd get to save their money in a US savings account and report no profit to be taxed on in the UK for corporation tax since there would be no profit to the LTD after founding the LLC which is investing into a savings account. Your UK LTD should become an MNC but, could be something to think about to get your money around for growth, that way, Uncle Sam should see this as a domestic tax issue and the LTD in Britain won't report a profit.

Unless OP is just a tax exile from the UK, in which case, OP owes the UK taxes so would be liable to letters asking OP to pay.

Where did you hear this fiction about PRC using north korea for laundering? If they wanted more money supply they could just call in some of the credit they extend america or like america or like america print some, but it pays them to devalue their own currency and inflate the dollar.

Actually the PRC dont need to launder anything abroad anywhere, their internal economy is vast and completely obscure, if they wanted to, but why would they want to ?

North Korea on the other hand is suspected to be forging american and other money, and as the recent murder of kim jomg ils brother highlighted, the family has major asian investments and a thriving arms industry.


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