The United States Internal Revenue Service (IRS) has released, in the form of Revenue Ruling 2011-19, the long awaited confirmation that the £30,000 remittance basis charge will be allowable as a credit for US income tax purposes, says Baker Tilly.
According to George Bull, Senior Tax Partner at Baker Tilly, the news will be well received by non-UK domiciled US taxpayers who have been resident in the UK for more than seven out of the last nine tax years and who have elected to use the remittance basis of taxation. Such election allows them to be taxed on non-UK source income and gains only to the extent they are remitted to the UK. "Up until now, these individuals have faced uncertainty in terms of whether a credit could be claimed against their US income tax bills in respect of the charge," says Bull. Baker Tilly points out that...
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