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Remittance basis charge

September 29, 2011

US citizens who are resident in the UK may be eligible to use the remittance basis when reporting their overseas income and gains to HMRC, which means such overseas income can escape UK tax. However, in most cases the US citizen must pay the remittance basis charge in the UK (£30,000 p.a) in order to use the remittance basis for a particular tax year. Until recently it was not clear whether the remittance basis charge could be set against US tax liabilities. The US tax authority: the Internal Revenue Service (IRS), has now confirmed the remittance basis charge can be set against US tax, see ruling 2011-19. 

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Internal Revenue Service Ruling 2011-19.