Private Equity & Carried Interest Tax Experts
Introduction Carried interest is one of the most politically contested and technically complex areas of US-UK cross-border taxation. A US citizen who is a fund manager or general partner based in the United Kingdom receives a carried interest that is subject to UK tax rules on the one hand and US federal tax rules — […]
Accountants for US and UK — Offshore Disclosure Guide
Introduction A US citizen living in the UK who holds undisclosed offshore accounts faces two separate disclosure obligations — one to the IRS and one to HMRC. Both tax authorities now receive account data automatically. Both have penalty regimes that escalate with delay. And neither disclosure route is designed with the other in mind — […]
IRS Streamlined Filing Experts — UK Stamp Duty for US Buyers
Introduction A US citizen buying a UK property faces SDLT rules that differ from every other UK buyer — because their residency status, their domicile, and whether they have resolved their US filing obligations all affect the stamp duty calculation and the US tax treatment of the acquisition cost. IRS Streamlined Filing Experts who advise […]
Streamlined Foreign Offshore: Wealth Protection
Introduction A high-net-worth US citizen relocating to the United Kingdom faces two simultaneous challenges. The first is the relocation itself — finding a home, transferring assets, establishing UK banking, and adjusting to a new financial environment. The second is the compliance gap, because most HNW Americans who move to the UK have not filed US […]
IRS Streamlined Filing Compliance — Non-Wilful Certification
Introduction The most consequential document in any IRS Streamlined Filing Compliance submission is neither the tax return nor the FBAR. It is the non-wilful certification — the signed statement under penalties of perjury that the taxpayer’s failure to comply was not deliberate. The certification is the gateway to the program. Without it, there is no […]
US Tax Amnesty Program for Americans Abroad — FBAR Guide
Introduction The FBAR is one of six documents required by the US tax amnesty program for Americans abroad. It is also one of the most commonly prepared incorrectly — because the rules governing which accounts must be reported, how the $10,000 threshold is calculated, and what the 2023 Supreme Court ruling in Bittner v United […]