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06 April 2010
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.
- 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?
- 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...
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