We understand the complexities that US citizens and other 'non-doms' face when living, working and running businesses in the UK or Switzerland.
We can also assist you if you are planning to relocate or expand your business in the US, or if you make investments which may be taxable in the US.
We are able to provide a comprehensive range of US and UK tax compliance and planning solutions for you, your family and your business. Each of our people understands the interaction of the competing UK US tax issues allowing you to engage with specialist advisers and their teams.
We can assist with the preparation of your US federal, state and local tax returns and with the maze of US compliance associated with interests in foreign financial accounts, corporations, partnerships and trusts.
We are able to help you plan your US tax affairs efficiently, so that you don't pay more than the 'right' amount of US tax and take full advantage of foreign tax credits, income exclusions and the provisions of any applicable tax treaty.
If you are starting or running a business, we can advise on the important US tax implications and help you plan to efficiently manage your combined effective worldwide tax rate.
We can assist with the preparation of your UK tax returns and advise you on the importance of your residence and domicile status.
We understand that if you are a 'non-dom', your UK tax position has become confusing and cumbersome and we can help you understand the impact of the ever-changing ‘non-dom’ legislation to maximise your UK tax position, including the key changes which take effect in 2017.
We can advise you on the remittance basis rules, whether to pay the Remittance Basis Charge and how double tax treaties can be applied to ensure you are not suffering double taxation. This is of particular importance to US taxpayers who are already subject to tax on a worldwide basis.
If you hold assets and investments, we can assist with the multi-jurisdictional tax planning which is key to maximising your investment strategy for you and your family.
If you are a US person, certain foreign investments can give rise to extremely penal tax rates and we can help you to avoid those traps.
We can assist with providing tax advice in respect of multi-generational wealth planning, including making lifetime gifts, settling trusts and undertaking joined-up US estate tax and UK inheritance tax planning.
In Switzerland, the banking landscape for both US citizens and UK residents has changed dramatically in recent times. We can assist you in ensuring that unnecessary withholding taxes are avoided and help you certify your tax status with your bank.
If you are starting or running a business in the UK or the US, we can provide a comprehensive suite of services including incorporation, bookkeeping, payroll, VAT, company secretarial services and the preparation of annual accounts and tax returns.
We can advise you on the most efficient structure for your business and how best to extract profits and capital value. We understand that you care about the combined, worldwide tax rate, and if you are a US person, that there are significant issues to be considered.
There are many Americans, who may have lived for years outside the US and who are fully compliant with their tax affairs in the country in which they live, but may have been unaware of their continued requirement to file US tax and information returns. There is also a category of ‘accidental’ American. Who is unaware of their US citizenship let alone their requirement to file tax returns. These individuals should be considering voluntary disclosure (approaching the IRS before they are found).
In an environment where legislation has been enacted that gives the US authorities unprecedented reach beyond their own borders and with a recent history of voluntary disclosure programs offered by the IRS, non-compliant taxpayers should be giving very serious consideration to getting back into the US tax system.
There are, very broadly, three voluntary disclosure options available. Two of these fall within formal IRS administrative programs: the 2012 Offshore Voluntary Disclosure Initiative (OVDI) and the Streamlined Procedures for ‘non-wilful’ cases. The third option is to file late tax returns outside of the programs because either you do not meet the criteria to enter into them, or the voluntary disclosure programs themselves are not appropriate to your circumstances.
We are able to help advise non-compliant US taxpayers on voluntary disclosure and the options available to them in achieving the goal of getting (back) into the system.
For a more in depth discussion of the options available please follow this link.