Hello,
I an neither UK nor US Citizen (and non-domiciled in the UK).
I worked for a US company in the US for a few years and just moved to the UK to work for the UK subsidiary of that same company. I have ceased working in the US and will only be there for short business trips to visit the US HQ. This means that in 2015 I will no longer be a resident of the US for tax purposes.
My salary is being paid in the UK, but I may receive a lump-sum bonus payment in 2015 and I could have the option of getting that paid in the US by the US company. If this were to happen, would this bonus be considered ECI or FDAP Income? Is there a way to structure this such that it is neither, and would I then be able to avoid paying tax on it?
Thanks!
