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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, November 7, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel and advisers with a practical guide to issues that arise in relation to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in the United Kingdom, as well as UK citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law and treaty provisions designed to avoid or mitigate dual taxation, give an overview of UK residence and domicile rules, and discuss treaty benefits.

Faculty

Kristin E. Konschnik
Partner
McLemore Konschnik LLP

Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and Connecticut). She enjoys learning about her clients’ circumstances and goals, and she works hard to make complex tax concepts more accessible so that clients are empowered to make informed decisions about what matters to them. Because Ms. Konschnik has practised in London for many years, she has significant experience helping clients navigate multiple tax systems. Her primary expertise is in working with owner-managed businesses in a cross-border context. Ms. Konschnik's clients include family-owned and closely-held businesses (and their owners), entrepreneurs, and private equity, real estate and venture capital fund principals. In addition to regular advisory work for her long-term clients, she frequently works with management teams in private equity buyout and roll-over transactions. 

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Jonathan Colclough
Partner
BDB Pitmans LLP

Mr. Colclough is a partner in the firm’s private wealth team. He advises both UK residents and international clients on UK tax, trusts, estate and succession issues with a particular focus on international cross-border matters for non-UK domiciled clients (resident in the UK or elsewhere), offshore trustees and family offices. This includes advising on residence, domicile, the remittance basis of taxation, and developing or refining structures and strategies to preserve wealth and avoid unnecessary tax and succession implications. Mr. Colclough is a member of the Society of Trust and Estate Practitioners (STEP) and has obtained the STEP Diploma and the STEP Advanced Certificate in UK Tax for International Clients and a STEP excellence award. He is named as a key lawyer in the leading legal directory Legal 500, and is ranked in Chambers in the High Net Worth Guide and as a lawyer with foreign expertise in South Africa. Mr. Colclough is included in the top 100 Crypto Advisers and managers curated by Citywealth as highly accredited.

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Inga Sviderskiene
Senior Manager, US/UK Private Client
Blick Rothenberg

Ms. Sviderskiene is a Senior Manager at Blick Rothenberg.

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Description

The U.S. and UK have significant economic and social ties resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges stemming from the interpretation and enforcement of U.S. and UK tax rules to avoid adverse tax liability from either country.

Among the most critical planning challenges for cross-border activities is reconciling the U.S. and UK rules governing residence and domicile. U.K. domicile rules are complex, and even inadvertent failure to meet filing obligations due to a misapplication of domicile rules can be costly. U.S. tax advisers serving clients with a presence in the U.S. and the UK will need to understand the domicile rules to avoid costly tax and penalties.

Another critical planning element is avoiding dual taxation on income and gains. The U.S. has detailed domestic foreign tax credit rules, along with a comprehensive tax treaty with the U.K. that together address most dual taxation concerns, but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill--or maybe two.

Other areas of concern in U.S.-UK tax planning include treatment of passive income and tax considerations of cross-border pension ownership, contributions, and withdrawals. Hovering over all these concerns are the extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations.

Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-UK cross-border tax planning and reporting issues.

Outline

  1. The U.S.-UK income tax treaty overview and dual tax mitigation provision
  2. Domicile and residency rules
  3. Passive and unearned income treatment
  4. U.S. tax reporting requirements of UK-sourced investments
  5. Limitation of benefit provisions

Benefits

The panel will review these and other important topics:

  • What are the applicable domestic and treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities and trusts?
  • Limitation of benefits clauses and provisions in the U.S.-UK income tax treaty
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of UK-sourced investments

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize U.S. tax reporting requirements for U.S. taxpayers residing in the UK
  • Establish the domicile of the taxpayer and whether tax treaty benefits are available based upon the determined domicile
  • Distinguish among the various tests used to determine whether a taxpayer is eligible for tax treaty benefits
  • Identify opportunities to mitigate dual taxation
  • Identify the limitations of benefits in the U.S.-UK tax treaty

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign information reporting requirements, including FATCA and FinCEN Form 114; familiarity with foreign income sourcing rules and tax treaty provisions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).