Capital Gains Planning for American Art Collectors
Capital Gains Planning for American Art Collectors Across the US and UK Effective capital gains planning for American art collectors begins by treating artwork as a tax category in its own right. Sell a painting held long-term, and the US caps the federal rate at 28%, not the 20% that applies to shares, while the […]
Form 3520 Foreign Trust Guide for US-UK Clients
Reporting Foreign Trusts on Form 3520: What Wealthy US-UK Clients Should Know Form 3520, Foreign Trust Return, is the form a US person uses to report dealings with a non-US trust or a large gift from abroad. For wealthy US-UK families holding UK family trusts, will trusts, or offshore structures, filing them correctly protects you […]
 PFIC Planning C-Suite Expats: Beat the Trap
How C-Suite Expats Structure Investments to Escape the PFIC Trap For PFIC planning, C-suite expats, everything comes down to where the money sits. Non-US pooled funds — UK OEICs, unit trusts, investment trusts, and ISA funds — are treated as passive foreign investment companies by the IRS. Executives escape the trap by holding US-domiciled funds, […]
Reduce Double Taxation: Authors With Royalties
How Authors With International Royalties Cut Double Taxation on Global Income Authors who earn across borders can legally reduce the double taxation they face by combining treaty withholding relief, foreign tax credits, and a totalisation certificate. The result: the same royalty amount, in pounds or dollars, is taxed once, not twice, and every reclaimable amount […]
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 […]
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 […]
Capital Gains Planning London Investment Bankers
Capital Gains Planning for London Investment Bankers Across the US and UK The capital gains planning London investment bankers genuinely need follows the calendar of their rewards, not a single tax return. Restricted stock vests in spring, a co-investment exits mid-year, carry crystallizes when the fund finally sells, and the portfolio is rebalanced at year-end. […]
High Earners FTC Not FEIE: The Smarter US Tax Move
Why High Earners Should Use the Foreign Tax Credit, Not FEIE The case for high-earners FTC rather than FEIE is simple for well-paid Americans residing in the UK: the Foreign Tax Credit typically eliminates your US payment, and banks save credits for future years, and it covers investment income that the exclusion ignores. The exclusion […]