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Topic: Looking for a US tax expert in Edinburgh -- speciality renunciation  (Read 3694 times)

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Hello all, Does anyone know of a good, reputable expert on US taxes/tax law who is based in Edinburgh or the US. I have become a German citizen and I am currently living in UK (please do not mention Brexit >:() and hope to be for some time. The Germans require that I renounce US citizenship and I need sound, accurate advice on when/how the renunciation date is set, how this could/might effect assets still held in the US (do I need to move them, should I move them), etc. I've been filing with the IRS regularly and I'm fairly certain I am up to date on FBAR for 2009 - 2014/2015 (became a German citizen in 2015). If you can recommend anyone, please do. Thanks and best regards, ET


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #1 on: August 04, 2016, 08:34:06 PM »
I am a dual German citizen and the German Embassy knew that the day I was re-naturalized as a German citizen.  They had no problem with my dual citizenship.  You may want to double check on your own facts. Did you relinquish your US citizenship the day you became German?  Have you looked here for a local tax adviser in Edinburgh: http://irs.treasury.gov/rpo/rpo.jsf
« Last Edit: August 04, 2016, 09:45:45 PM by guya »


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #2 on: August 04, 2016, 08:39:15 PM »
I believe that if you become a naturalized German citizen there is no requirement to renounce previous citizenships.


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #3 on: August 05, 2016, 03:16:14 PM »
I am a dual German citizen and the German Embassy knew that the day I was re-naturalized as a German citizen.  They had no problem with my dual citizenship.  You may want to double check on your own facts. Did you relinquish your US citizenship the day you became German?  Have you looked here for a local tax adviser in Edinburgh: newcomer link: http://irs.treasury.gov/rpo/rpo.jsf [nonactive]
Thanks very much for that ... I started out as a naturalized US citizen (born in US). The Einwanderungsbehörde in Berlin are absolutely clear that I must relinquish my US citizenship/passport by the end of this year. The US authorities have informed me that the relinquishment will be back-dated to the day I obtained German citizenship (swore an oath of allegiance to another country). So I'm going to have to go through with it ... sad, but that's the way it is. Thanks again for getting in touch.


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #4 on: August 05, 2016, 03:18:14 PM »
I believe that if you become a naturalized German citizen there is no requirement to renounce previous citizenships.
Thanks very much for your reply. The German authorities have been absolutely clear that I must relinquish my US citizenship ... but thanks for getting in touch anyway.


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #5 on: August 05, 2016, 07:23:35 PM »
Hello all, Does anyone know of a good, reputable expert on US taxes/tax law who is based in Edinburgh or the US.

My tax guy is a US/UK expert based in the US. I can highly recommend him.

Let me know if you are interested and I will pm you his details.  :)
« Last Edit: August 05, 2016, 07:24:53 PM by larrabee »


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #6 on: August 05, 2016, 07:39:29 PM »
My tax guy is a US/UK expert based in the US. I can highly recommend him.

Let me know if you are interested and I will pm you his details.  :)
Thank you very much ... I am interested. What is pm? Best regards, ET


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #7 on: August 05, 2016, 08:22:43 PM »
Thank you very much ... I am interested. What is pm? Best regards, ET

pm = personal message

I will send you one with his details.


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #8 on: August 06, 2016, 02:06:27 PM »
Most UK based individuals who do not feel confident handling their own tax returns will want to check that any proposed tax adviser is qualified with at least one professional accounting or tax professional body in the UK as well as in the United States so that they know that the adviser is adequately regulated in the UK and handles every day many of the complexities of the foreign aspects of the United States tax system.  Indeed, more broadly, for most UK based individuals there are often considerable advantages in having a UK based adviser who can jointly advise on both US and UK tax issues and (possibly) handle both sets of tax returns in the UK.

These include:
1.   The client and the adviser being located in the same time zone.
2.   Client documents and workpapers being held outside of the United States; which many people perceive as providing additional protection in the event of IRS audits.
3.   Advisers outside of the UK are unable to offer the protections to clients provided by the UKs Proceeds of Crime Act, which requires all tax professionals in the UK to be regulated and supervised for anti-money laundering protection purposes.  Here in the UK it is a criminal offence to offer tax advice unless the adviser is supervised. Quite unlike within the UK, there is no requirement for mandatory regulation of tax advisers in most of the United States. 
4.   The fact that although there are roughly one million paid tax professionals within the United States, that there are naturally only very few amongst these who understand enough about the US reporting of foreign based taxpayers.
5.   Most tax advisers outside of the UK are not bound by the UK ethical standards that govern UK qualified advisers; which set out fundamental principles of integrity, objectivity, competence and care, confidentiality and behaviour (http://www.tax.org.uk/professional-standards/professional-rules/professional-conduct-relation-taxation).
6.   The opportunity in the unlikely event that things ever go wrong to get issues addressed through a supervisory body that is closer to the client than an adviser located several thousand miles away.

The IRS have an excellent Directory that lists all US qualified tax professionals here in the UK: http://irs.treasury.gov/rpo/rpo.jsf


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Re: Looking for a US tax expert in Edinburgh -- speciality renunciation
« Reply #9 on: August 07, 2016, 11:44:07 AM »
The following may be of some assistance to E T Toro.

Arlene Reid of cleartaxation in Edinburgh is a registered US tax return preparer. For the avoidance of doubt, I have no connection with her or her firm.

Bloomsbury recently published a book entitled “Guide to US/UK Private Wealth Planning”. There is a succinct summary of the US expatriation tax rules in Chapter 18.




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