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Topic: UK equivalent of TurboTax?  (Read 3077 times)

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UK equivalent of TurboTax?
« on: January 12, 2014, 10:43:20 AM »
Hey guys

I've been in the UK on Indefinite Leave since January, 1998.  Have had minor dividend income from the US every year as well as UK employment,  filed and paid on UK side using HMRC online, not a problem.

For the 2012-2013 tax year I sold some US assets (bullion and shares) and fully paid US taxes on those sales.

I use Turbo Tax on the US side, and never felt the need for anything beyond the HMRC online software until this year.  I'm having difficulty getting the HMRC stuff to credit my US side payments. 

Is there a UK equivalent of Turbo Tax that will recognise and fully credit for US taxes already paid? 

My specific problem with the HMRC software is that I'm using form HS261 offline to calculated foreign tax credit, some of this stuff is taxed higher in the US meaning 100% of the tax paid should be credited, but it seems on the online software (at least the way I'm using it) ignores taxes already paid.

thanks


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Re: UK equivalent of TurboTax?
« Reply #1 on: January 12, 2014, 03:45:20 PM »
HMRCs free software can never be used by anyone who is domiciled outside of the UK; as it does not support the relevant pages (irrespective of whether one is filing on an arising or remittance basis). Since you have only been here since 1998 it would seem unlikely that you domiciled within the UK; so would need to use a professional adviser or purchase commercial software.

You also have a common misunderstanding of the tax on capital gains. Under Article 24 of the US/UK treaty the gains are "resourced" as foreign on your US income tax and the US will then give credit for UK tax payable. The UK does not give credit for US tax on such capital gains.

If you did not pay the UK CGT by 31 December 2013; you will need to file an amended 2013 US return during 2014 to carry back excess foreign tax credit in the treaty resourced basket from your 2014 US tax return.


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Re: UK equivalent of TurboTax?
« Reply #2 on: January 12, 2014, 10:31:51 PM »
I think this shows that software is not the whole solution when it comes to cross border taxation. The gains from US investments held by a UK resident are primarily taxable in the UK and any UK tax paid is then used as a credit against US tax. The gains would have to be greater than your UK capital gains allowance for there to be any credit, that's assuming that the investments are UK reporting and are not taxed as income by HMRC. For US dividends the situation is a bit different as the US gets paid a minimum percentage of tax as per the treaty.

Gains from the sale of real property situated in the US owned by a UK resident would be primarily taxed in the US.
« Last Edit: January 12, 2014, 11:04:54 PM by nun »


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