I am expecting to move to the UK in mid June. Once there, I intend to file my UK taxes on the remittance basis under the non domiciled resident status. One thing which is not very clear to me is the tax treatment of dividends on UK listed shares. My understanding is that this classifies as "UK source income" and thus taxable in UK despite my non domiciled status.
However, what I can't figure out is that do I pay tax first to the US and use that tax credit when paying tax in the UK (given earlier filing deadline in US). The problem with this approach is that I won't have paid tax on any dividends rcvd between 1st Jan 16 - 5th Apr 16. Also, I expect to pay US dividend tax at the 20% rate and I believe UK only gives credit up to 15% (I am expecting to pay the dividend tax at highest rate in UK).
The other way is that I pay UK tax first and use as credit when I file my US return. However, this means that I will have to pay the dividend tax before 31st December. There is zero withholding at time of dividend payment and so it feels like I have to make separate payments (is there an equivalent of estimated tax payment in the UK).
Above is assuming I am using the cash method for credits on my general income (does that mean I can only use the cash method then on passive income).
If I am able to make estimated tax on the dividends in the calendar year 2015, do I get some documentation from the UK tax authorities to keep as proof of the same in case the IRS asks (just like I would have wage slips for regular income)?
Is there a restriction on which approach I can follow as per US-UK tax treaty (in other words, which country has priority in receiving dividend tax in this case (UK source dividend, US citizen resident in UK).
In short, I am trying to figure out a way I don't end up with double taxation and don't have to file any amended returns to claim that back.
Thanks!