Taxation logo taxation mission text

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

Readers’ forum: Foreign profits

13 April 2021
Issue: 4787 / Categories: Forum & Feedback
UK tax on US property proceeds and foreign income.

I have recently been approached by a high net worth husband and wife who have financial interests in several jurisdictions. They have US passports and are of Korean heritage but both of them live in the UK and I am certain that they are UK tax resident.

The husband is UK domiciled but the wife is not and will soon fall foul of the seven out of nine-year rule.

They are limited partners in a NY LLC which holds residential real estate. They plan to incur very significant costs in improving the property (in the region of $1m) and will then rent it out before selling it. For US tax purposes they are treating the distributions from the LLC (both in respect of rent and the ultimate disposal proceeds) as a return of capital.

I am not advising on the US tax aspects but would like to...

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