PFIC Planning US Surgeons in Britain | Jungle Tax
How US Surgeons in Britain Structure Investments to Escape the PFIC Trap Effective PFIC planning for US surgeons in Britain means holding US-domiciled funds in a US brokerage, directly holding individual shares, and using treaty-protected pensions, while avoiding UK OEICs, unit trusts, investment trusts, and ISA fund holdings that would trigger punitive US tax under […]
US Tax Deadlines Expats Must Diarise in 2026
US Tax Deadlines for Expats: What Wealthy US-UK Clients Should Know The US tax deadlines expats must meet do not stop at 15 April. Living in the UK automatically grants an extension to 15 June. However, interest still runs from April, FBAR and foreign-trust forms follow their own calendar, and everything sits awkwardly against the […]
Streamlined vs Voluntary London Investment Bankers Guide
Streamlined vs Voluntary Disclosure: What London Investment Bankers Should Weigh The choice of streamlined vs voluntary that London investment bankers face comes down to one word: wilfulness. If your missed US filings were genuinely non-wilful, the Streamlined Foreign Offshore Procedures carry a 0% penalty. If the conduct was wilful or you cannot honestly certify otherwise, […]
Trust Planning for HNW Americans in the UK
Trust and Inheritance Planning for HNW Americans in the UK Effective trust planning for Americans in the UK means satisfying two tax authorities at once: the IRS taxes you on worldwide assets as a US person, while HMRC now taxes you on residence rather than domicile. A structure that saves tax in one country can […]
Trust Planning Tech Founders After an Exit
Trust and Inheritance Planning for Tech Founders After an Exit Effective trust planning for tech founders after an exit depends on acting before the wire clears: once your shares turn to cash, the US charges estate and gift tax at 40%, and the UK adds inheritance tax at 40%, so a well-timed trust can move […]
FBAR Catch-Up High-Earning US Consultants: One Filing
FBAR Catch-Up for High-Earning US Consultants: Years of Foreign Accounts, One Filing The FBAR catch-up high-earning consultants‘ route lets you resolve several years of unreported foreign accounts through a single Streamlined submission, usually with a 0% penalty when your conduct was non-wilful. You file three amended returns and six years of FBARs together, then certify […]