UK & US
Both the UK and US have demonstrated a shared desire to combat tax evasion in recent years. This has led to increasingly complex rules which, combined with greater scrutiny from the tax authorities, has significantly expanded the compliance burden for taxpayers.
At Citrine International we seek to provide a bespoke tax compliance solution specific to a client’s needs and circumstances. Our team is experienced in both UK and US tax compliance and has is familiar with analysing the domestic laws of both jurisdictions as well as the UK/US Double Tax Treaty. Our processes and communications are designed to make cross-border tax compliance as clear, transparent and manageable as possible.
UK: Income Tax Returns
We offer income tax return preparation services to the following:
- UK resident and non-domiciled individuals
- UK resident taxpayers who have become domiciled in the UK (deemed or actual)
- Individuals who are non-resident with UK source income
We can also assist with the following HMRC forms:
- Registering for self-employment
- Registering for National Insurance
- Non-resident landlord forms
- Tax specific elections (e.g. the foreign capital loss election)
UK: Offshore Disclosure
HMRC has declared that from 30 September 2018 it will toughen its approach to individuals who have undeclared offshore income. This is the date from which HMRC has access data from over 100 countries that have agreed to share information. We understand that, no matter how careful a taxpayer may have been when operating on their own, mistakes can easily have occurred. We work with our clients to calculate any exposure and communicate with HMRC to help mitigate potential penalties.
US: Income Tax Returns
We are experienced in preparing US Federal returns for the following:
- US citizens and ‘greencard’ holders (whether residing in or out of the US)
- US non-resident aliens
- US resident aliens or ‘Dual Status’ aliens
We also prepare state tax returns for residents and non-residents as and when required.
US: Bank Account Forms
We provide assistance to our clients with the preparation of their Report of Foreign Bank and Financial Account forms (Forms FinCEN114), also known as ‘FBARs’. Completion of form 8938 (Statement of Specified Foreign Financial Assets) is part of our standard income tax return preparation service.
US: Disclosure Programmes
With foreign banks now having to report the income of US citizens to the IRS it is only a matter of time before the IRS begins to contact non-compliant taxpayers. We work with our clients to understand their backgrounds and motivations for their failure to file. This enables us to offer a full assessment so a client can decide which IRS programme is best for them to bring their tax affairs up to date.
In certain circumstances it may be possible for a client to bring their affairs up to date with minimum exposure to penalties using the IRS ‘Streamlined Foreign Offshore’ procedure.
If a US citizen, or someone who has held a ‘greencard’ for at least 8 out of the previous 15 years, decides to relinquish their citizenship or residence we work with them, and their lawyers, to minimise the tax impact. This includes an assessment of net worth and preparation of the necessary tax return forms. These would include the ‘dual status’ income tax return and Form 8854 (Initial and Annual Expatriation Statement) for the year of expatriation.
US: Trusts, Gifts and Estates
Whether a US client is a settlor or beneficiary of a foreign trust, which could include a Self-Invested Pension Plan (SIPP) in the UK, or has made gifts or received gifts from non-resident aliens during the year, we can file (if needed) the following information returns on their behalf:
- 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts)
- 3520-A (Annual Information Return of Foreign Trust with a U.S. Owner)
- 709 (Gift Tax Return)
US: Business Related Forms
Once we have advised privately owned businesses and partnerships how to be structured from a tax perspective, we are able to prepare the following tax return forms:
- 8832 (Entity Classification Election)
- 5471 (Information Form for Certain Foreign Corporations)*
- 8865 (Information Form for Foreign Partnerships)
- 8858 (Information Form for Foreign Disregarded Entities)
*Preparation of forms 5471would involve an analysis of controlled foreign corporation status, their subpart F income, and the exposure of their owners to the ‘GILTI’ tax.