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My client is the executor and principal residuary beneficiary of a substantial UK estate. During the tax year 2020/21 the estate received dividends from US quoted securities totalling £100 000. These suffered 30% US withholding tax.
I assume that the executors are free to make a claim to the IRS in full under the UK/US double tax treaty to repay the difference between the 30% tax paid and the 15% maximum withholding tax charge stated in Article 10 of the treaty.
When disclosing the dividends in the 2020/21 estate tax return I have limited the tax credit to the dividend basic rate of 7.5% as this is the maximum rate of tax payable by the estate.
The residuary estate will be distributed in full in 2021/22 and my question relates to the entries to be made on the R185. First should the entries be made in either box 18...
