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US citizens can offset remittance charge

18 August 2011
Issue: 4318 / Categories: News , IRS , USA , Residence & domicile
IRS issues 'pragmatic' ruling

The Internal Revenue Service (IRS), the tax authority of the United States, has issued a document to confirm that US taxpayers can claim credit for the UK's remittance basis charge.

The publication of Revenue Ruling 2011-19 means American citizens who are resident in this country and choose to pay tax on the remittance basis can set against their US tax bills the annual £30,000 charge levied by HMRC.

Given the IRS taxes US citizens and green card-holders on their worldwide income, regardless of where they live, American non-doms living and working in the UK previously ran the risk of being taxed twice on the same income.

The situation should now be eliminated, said Dan Crowther, director in the private client advisory practice at KPMG in the UK, who praised the ’sensible and pragmatic ruling’.

Issue: 4318 / Categories: News , IRS , USA , Residence & domicile
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