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News – 10.04.24

Form PF: Are you up to speed with the latest developments?

Through this insight we will bring to your attention the main changes in a bitesize manner so that you can stay abreast of the requirements as they may apply to your firm. … Read more

Insight – 16.04.24

US and UK tax on carried interest

Learn more about the opportunities to minimise double taxation for dual US/UK taxpayers … Read more

Upcoming event – 29.04.24

Governance code updates and advice for Further Education colleges from Buzzacott and the ESFA

Join Buzzacott and the ESFA for a governance update for further education colleges … Read more

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Advice for US citizens setting up a business in the UK

Due to the complex cross-border tax legislation between the US and UK, there is no one size fits all solution, and there are many variables to consider before making any decisions.

In this video, Paul Baker and Meera Shah highlight the key considerations for US citizens looking to set up a business in the UK. Take a look at the Stepping Stones article below for more information, including a case study on how the process works in practice.

If you're a US shareholder of a controlled corporation (CFC), meaning you own more than 50% of the total value or combined voting power of a company based outside of the US, you should be aware of Global Intangible Low Taxed Income (GILTI) - take a look at this article for more information.

https://www.youtube.com/watch?v=XpQT1doQiAM

The impact of GILTI

You might also be interested in… Stepping Stones: US citizens setting up a UK business

When thinking about setting up a UK company, there is no one size fits all solution, and of course there are many variables to consider before making any decisions. If you have already established a UK company, it would be wise to consider how the 2018 tax reforms impact your global tax bill and whether an alternative type of business structure would be preferable.

Without careful consideration and advice, the complexity of US/UK cross-border tax rules could see more of your hard-earned money go straight to the pockets of the taxman!

The case study below includes examples of how we helped our client, which includes advice on four key areas of US tax:

Form 8832 is the entity classification election, known as the 'check-the-box' election
Controlled Foreign Corporation (CFC) rules, including, Subpart F anti-avoidance rules
Passive Foreign Investment Company (PFIC) rules and tax treatment
Global Intangible Low Taxed Income (GILTI)

About the author

Paul Baker

+44 (0)20 7556 1391
bakerp@Buzzacott.co.uk
LinkedIn

Without careful consideration and advice, the complexity of US/UK cross-border tax rules could see more of your hard-earned money go straight to the pockets of the taxman!

The case study below includes examples of how we helped our client, which includes advice on four key areas of US tax:

Form 8832 is the entity classification election, known as the 'check-the-box' election
Controlled Foreign Corporation (CFC) rules, including, Subpart F anti-avoidance rules
Passive Foreign Investment Company (PFIC) rules and tax treatment
Global Intangible Low Taxed Income (GILTI)

Advice for US citizens setting up a business in the UK

Paul Baker

Read more…