Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

S bends

06 April 2010
Issue: 4249 / Categories: Forum & Feedback
A UK resident, but non-domicile, is a shareholder in an S corporation in the USA

A client is a shareholder in an ‘S corporation’ in the USA. The company owns a motel. Being an S corporation it pays no tax but the shareholders pay tax on the profit and gains made by it.

My client has submitted a Virginia non-resident income tax return in the USA. In 2008 he paid US tax on profit interest and capital gains made by the corporation. Paying the UK non-dom charge of £30 000 is not cost effective. My questions are as follows.

  1. Even though the corporation has made the profits and gain our client has not received anything; does he need to declare this in his UK tax return?
  2. Are there any double taxation treaties between the USA and the UK whereby income or gains taxed by the USA are not subject to further tax in the UK even if...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon