British Expats

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-   -   UK Tax advice in USA (San Francisco) (https://britishexpats.com/forum/usa-57/uk-tax-advice-usa-san-francisco-900827/)

ukexpatinSFO Jul 29th 2017 8:14 pm

UK Tax advice in USA (San Francisco)
 
Hello,

This is my first post to the forum but I have found it very useful to read other posts. I apologise if this is the wrong place to post this request.

I am living in San Francisco and I am looking for a recommendation for someone to help me file my UK tax return for the year ending April 2017. I would ideally also like the same person/firm to help with my US returns for 2017, when they are due.

I have lived full time in California since the beginning of 2016 and as part of my relocation package I have, up to now, had tax advice. However this benefit has now ended so I need to make my own arrangements to file my returns for now on.

I am on a L1A Visa and my employer has started the process to sponsor a green card.

I have a rental income in the UK on what was my primary residence. I am not yet sure how long I will stay in the US or if/when I would return to the UK. Beyond any help with filling UK and US tax returns I may want some advise on what to consider if I sold my property in the UK or decided to pay down the mortgage which would give me a higher income in the UK but this is not a priority.

Can anyone point me in the right direction? Is there a significant benefit for having the same firm/person help me with both US and UK tax?

Many thanks,

mrken30 Jul 31st 2017 4:23 am

Re: UK Tax advice in USA (San Francisco)
 
Have you registered as a non-resident landlord, NRL1? https://www.gov.uk/tax-uk-income-live-abroad/rent

You will need to be depreciating your UK residence.

Then reading through this should give you a basic outline of what is required.

https://money.usnews.com/money/blogs...ental-property

The UK gets first bite of the taxes, but you may or may not get double taxed by your state. Rental income is exempt in the treaty.

Dominic0012 Jul 31st 2017 10:32 pm

Re: UK Tax advice in USA (San Francisco)
 
I have a business relationship that i have with firm who deals with both U.S. & U.K. tax filings if you are interested.

To tackle the issue you raised you may want to consider the impact of selling your property and the effect that it will have on your estate, as you will lose the RNRB uplift.

when you become a green card holder you will remain a U.K. domicile so your estate will not get an RNRB uplift in the event of you selling your U.K. property.

PilgrimPete Aug 8th 2017 12:15 am

Re: UK Tax advice in USA (San Francisco)
 
Hi Dominic0012, this is exactly what I'm looking for - someone based in the Bay Area who can help us file our UK tax returns. If you could PM me the details of your business associate, or provide a little more information, I would be interested in getting in contact with them.

thanks,

PP

PS. I'm now wondering whether ukexpatinSFO is actually my wife asking the same questions as me!

Rete Aug 8th 2017 12:26 am

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by PilgrimPete (Post 12311767)
PS. I'm now wondering whether ukexpatinSFO is actually my wife asking the same questions as me!

I was wondering if you had forgotten your original user name and had signed up a second time :lol:

Would your wife had found the answer and not told you about it?

PilgrimPete Aug 8th 2017 12:43 am

Re: UK Tax advice in USA (San Francisco)
 
Ha ha, I wouldn't put it past her to be honest :D

PetrifiedExPat Aug 8th 2017 12:39 pm

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by Dominic0012 (Post 12306534)
I have a business relationship that i have with firm who deals with both U.S. & U.K. tax filings if you are interested.

To tackle the issue you raised you may want to consider the impact of selling your property and the effect that it will have on your estate, as you will lose the RNRB uplift.

when you become a green card holder you will remain a U.K. domicile so your estate will not get an RNRB uplift in the event of you selling your U.K. property.

I am a GC holder, looking to obtain citizenship in 2 years and remain in the US for the (long) foreseeable future.

I am thinking about drafting wills with my wife, how exactly do I shift from UK to US domicile. I worry about her British tax burden if something happens to me.

p.s. she is a US citizen and has only ever been in the UK as a tourist, 3-4 weeks in total.

Cook_County Aug 8th 2017 1:07 pm

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by PetrifiedExPat (Post 12312071)
I am a GC holder, looking to obtain citizenship in 2 years and remain in the US for the (long) foreseeable future.

I am thinking about drafting wills with my wife, how exactly do I shift from UK to US domicile. I worry about her British tax burden if something happens to me.

p.s. she is a US citizen and has only ever been in the UK as a tourist, 3-4 weeks in total.


From a US estate tax perspective there is a rebuttable presumption that a green card holder is US domiciled. From a UK perspective a domicile of origin is "sticky" and "tenacious". Even being interested in this discussion forum suggests you may not have shed your domicile of origin within the United Kingdom. You may therefore wish to study the US/UK estate tax treaty to see if this may assist.

PetrifiedExPat Aug 8th 2017 1:13 pm

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by Cook_County (Post 12312101)
From a US estate tax perspective there is a rebuttable presumption that a green card holder is US domiciled. From a UK perspective a domicile of origin is "sticky" and "tenacious". Even being interested in this discussion forum suggests you may not have shed your domicile of origin within the United Kingdom. You may therefore wish to study the US/UK estate tax treaty to see if this may assist.

My failings in dealing with tax put me in a bad position a few years back, since I misinterpreted the treaty, sadly. My current plan would be..

- sell my parents house once they pass (immediately),

- once US citizenship is obtained, not renew British passport or register to vote again (in UK)

- once US citizenship is obtained, close British bank accounts

- remain in US for 15 of the past 20 years (before I pass, I know I can not predict that of course!)

- only ever enter with US passport

From a naive point of view, I thought that would be a good start..?

EDIT: buying US home this year, too. My first residence I will have owned.

Dominic0012 Aug 8th 2017 2:47 pm

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by PetrifiedExPat (Post 12312071)
I am a GC holder, looking to obtain citizenship in 2 years and remain in the US for the (long) foreseeable future.

I am thinking about drafting wills with my wife, how exactly do I shift from UK to US domicile. I worry about her British tax burden if something happens to me.

p.s. she is a US citizen and has only ever been in the UK as a tourist, 3-4 weeks in total.

You do not shift from a U.K. domicile to a U.S. Domicile in the event of a change of citizenship. It changes based on length of residence.

The IGA between the U.K. and the U.S. on estate tax ratifies the HMRC Deemed domicile rule in the event of a dual domicile between the U.S. and the U.K.

Are you in the U.K. at the moment or in the U.S. as a GC holder? If you are in the U.S. how long have you been in the U.S.?

PetrifiedExPat Aug 8th 2017 3:36 pm

Re: UK Tax advice in USA (San Francisco)
 

Originally Posted by Dominic0012 (Post 12312160)
You do not shift from a U.K. domicile to a U.S. Domicile in the event of a change of citizenship. It changes based on length of residence.

The IGA between the U.K. and the U.S. on estate tax ratifies the HMRC Deemed domicile rule in the event of a dual domicile between the U.S. and the U.K.

Are you in the U.K. at the moment or in the U.S. as a GC holder? If you are in the U.S. how long have you been in the U.S.?

Thank you for the reply.

I left to live in the US 8 years ago. First 5 years as a visa holder, then a return for 6 months to the UK to process a second visa, before returning and living here (US) ever since. GC holder for just shy of one year.

Just to clarify, now living permanently in US, the assumption being that will not change for many years (not at all, basically).

mrken30 Aug 8th 2017 4:36 pm

Re: UK Tax advice in USA (San Francisco)
 
This has raised a thought. If I die , is there any way my USC wife can get residency in the UK if my dual kids decide to move to the UK?


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