Has anyone used Artio Partners for tax prep? Income Re-Sourced by Treaty

My US taxes for 2013 will acquire additional complexity because now that I am a UK resident I will need to use Income Re-Sourcing to have any hope of minimizing double taxation.  This is accomplished on Form 1116, Foreign Tax Credit, (d) Certain Income Re-Sourced Under Treaty.  I will need this for for Dividends, Interest, and Capital Gains generated in the US.  This is an approach to minimizing double taxation that is mentioned by very few, if any, US/UK expat tax firms on their websites. 

From their websites, and also from several inquires I have made, it appears that most such firms are set up to do "cookie-cutter" tax prep for US expats who have UK earned income (employment) and can therefore benefit from Form 2555, Foreign Earned Income Exclusion.  My impression is that venturing beyond Form 2555 would require many firms to do "research" to determine what to do.  Is this an accurate impression?  Does anyone know if any of the following firms, which were recommended by fellow-member, NUN ( newcomer link: http://talk.uk-yankee.com/index.php?topic=79648.0 [nonactive] ), would be competent in this area?

newcomer link: http://www.britishamericantax.com [nonactive]
newcomer link: http://www.americantaxreturns.co.uk/ [nonactive]
newcomer link: http://britishexpatstax.com [nonactive]

Artio Partners is a US CPA firm, versus some of the others that are Enrolled Agents.  Income Re-Sourcing is more commonly used by businesses than by individuals.   Businesses need to have their financials signed by a CPA so I would hope Artio's CPA qualification implies a somewhat higher level of expertise in this area (no disrespect to EAs intended).

Thank you in advance for your comments.

CSRote

As this is the first question you have asked and you have not mentioned your background this is tough to answer.

Generally speaking double taxation does not occur in the first 7 years of UK tax residence because one would claim the remittance basis on the UK return; so resourcing of income sufficient to avoid double taxation is not a concern.

For later years if double taxation does occur one would hope that any competent adviser would be familiar with Article 24 of the US/UK tax treaty.

It is difficult to comment on any US based adviser suffice to say that they would presumably be trading without complying with the European Union Third Directive on Money Laundering; legislated in the UK under the Proceeds of Crime Act as the Money Laundering Regulations 2007. It would seem inappropriate to suggest doing business with an entity that is not compliant with UK law if one is UK resident.

http://www.britishamericantax.com
http://www.americantaxreturns.co.uk/
http://britishexpatstax.com

I believe that the companies quoted above are all very experienced and would be easily able to deal with your situation, but the way to find out is to ask them.

FYI there is an example of income resourcing that you might find useful in the link below on page 104.

http://www.treasury.gov/resource-center/tax-policy/treaties/Documents/teus-uk.pdf

Hi CSROte,

Realise this is a very old thread, but I am a US citizen retired in the UK and am struggling to understand the Form 1116 as it applies to taking a tax credit, and particularly if it applies to income covered by a tax treaty.  There is a statement in the very long IRS publication 514 (for the 1116) which says that tax treaties may allow income resourcing from one contracting state to the other, but I cannot find any information further.  Have you had any luck with the firm you chose?

Mike

Hi CSROte,

Realise this is a very old thread, but I am a US citizen retired in the UK and am struggling to understand the Form 1116 as it applies to taking a tax credit, and particularly if it applies to income covered by a tax treaty.  There is a statement in the very long IRS publication 514 (for the 1116) which says that tax treaties may allow income resourcing from one contracting state to the other, but I cannot find any information further.  Have you had any luck with the firm you chose?

Mike

First you should determine your tax status in the UK and whether you will be taxed on a remittance or arising basis.

Use of Form 1116 (Foreign tax credits) can get a bit complicated if you have different sorts of income like earned vs passive and dividends and capital gains. The Treaty dictates exactly how the various types of income will be resourced. So you should first list all your sources of income and the categories they fall into for Form 1116 and then look at the relevant Articles in the US/UK Tax Treaty.

If things get too complicated your first port of call might be the US Embassy tax service and then a professional adviser.

Hello TheMike

Roger B. Adams is an Enrolled Agent located in Portugal who has particular expertise in the Foreign Tax Credit and its associated Form 1116.  He has written a very helpful article about the FTC which can be found at
newcomer link: http://americansabroad.org/issues/taxation/article-on-foreign-tax-credit-revised/ [nonactive]

Unfortunately he is no longer accepting new clients. He wrote the following to me:

"I can recommend a colleague who is quite capable in this area and practices in the UK. 
Her name is Liz Zitzow and the website for her company is here  newcomer link: http://britishamericantax.com/  [nonactive]  . 
If you do contact her, tell her I sent you.
Best regards,
Roger B. Adams, EA"

I have not followed up on Liz Zitzow so can provide no feedback. 
Hope this helps all and sundry.

Liz Zitzow is the principal at British American Tax and has contributed to this and other international tax sites. From her posts I believe her to be very knowledgeable and professional. She, along with Guya and SaraSmiles, has greatly aided  the US expat on taxation issues.

Liz Zitzow is the principal at British American Tax and has contributed to this and other international tax sites. From her posts I believe her to be very knowledgeable and professional. She, along with Guya and SaraSmiles, has greatly aided  the US expat on taxation issues.

+1

Well said, nun.