PFIC Planning London Investment Bankers Guide
How London Investment Bankers Structure Investments to Escape the PFIC Trap The PFIC planning London investment bankers need starts with one hard rule: never hold pooled non-US funds. The punitive passive foreign investment company system under §1297 applies to US citizens who possess UK OEICs, unit trusts, investment trusts, or ISA funds. The escape route […]
Net Investment Income Tax: A US-UK Guide
Net Investment Income Tax: What Wealthy US-UK Clients Should Know The net investment income tax is a flat 3.8% US tax on the lesser of your net investment income or the amount by which your income exceeds a fixed threshold. For US citizens living in the UK, it can quietly tax the same dividends, gains […]
Reduce Double Taxation C-Suite Expats Face
How C-Suite Expats Cut Double Taxation on Global Income A senior executive who lives in one country and is taxed by another can watch the same pound get taxed twice. To reduce double taxation, C-suite expats rely on three levers: the US foreign tax credit, the US-UK treaty, and workday-based sourcing of equity pay. Used […]
 Streamlined vs Voluntary Authors With International Royalties
Streamlined vs Voluntary Disclosure: What Authors With International Royalties Should Weigh An author who has fallen behind on US filings usually has two supervised routes back into compliance: the Streamlined Filing Compliance Procedures for non-wilful conduct, and the Criminal Investigation Voluntary Disclosure Practice for wilful conduct. The core of the streamlined vs voluntary authors with […]
Capital Gains Planning for Retired US Executives Abroad
Capital Gains Planning for Retired US Executives Abroad Across the US and UK Capital gains planning for retired us executives abroad is the discipline of unwinding a career-built portfolio, concentrated stock, RSUs, funds, and a second home, across two tax systems at once. Sequence disposals against your US 0/15/20% brackets, the 3.8% NIIT, and UK […]
Streamlined Filing for Private Equity Executives
Streamlined Filing for Private Equity Executives: The Confidential Route to IRS Compliance For a US-connected fund partner who has quietly fallen behind, the streamlined filing private equity executives rely on offers a penalty-free, non-wilful path back to the IRS. It clears years of unreported carried interest, K-1s,s and offshore fund accounts through one discreet, professionally […]