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Topic: UK Double Tax Relief  (Read 1119 times)

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UK Double Tax Relief
« on: February 21, 2006, 10:53:05 PM »
I am a US/UK citizen working here in the UK primarily and the US occasionally. I know that the US will assert taxing rights over my income and I will get foreign tax credits on my foreign source income. However, will the UK do the same on my US source income?? Would I get some type of foreign tax credit here. I've gone through the "Help Sheets" on HMRC's website and it's not really helped me very much.

Many thanks.



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Re: UK Double Tax Relief
« Reply #1 on: February 21, 2006, 11:21:22 PM »
OK - this is real complicated!

Because you are a US citizen you report worldwide income in the US, but get to take the foreign earned income exclusion and foreign tax credits on foreign source income.

The UK makes you report worldwide earnings too; but gives a double tax credit for non-UK taxes on income that has been doubly taxed (eg by the UK and the US).

However the income attributable to US workdays is (generally speaking) not US source because under the double tax treaty it is dealt with as if it was UK source income by BOTH the UK and US tax authorities.  This requires treaty resourcing on your US tax returns and eliminates double tax relief in the UK (except for State taxes due on income relating to US workdays.

If this sounds complicated then that is because it is; a dual UK/US qualified tax adviser should be familiar with this.


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Re: UK Double Tax Relief
« Reply #2 on: February 22, 2006, 10:06:26 PM »
Thanks Guya. Very helpful. But one last question. How does one go about resourcing income on the US return?? I take it to mean the US workdays would be resourced to foreign income and I would be allowed to take UK tax credits against it on my US income tax return?

M ???


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