US & UK Tax Articles

  TAX • CROSS-BORDER • 2025 Summary: British buyers of US property face dual-jurisdiction tax exposure — the IRS taxes the US sale, and HMRC taxes the worldwide gain. US Realtors need cross-border planning support to avoid FIRPTA withholding traps, double taxation, and legal liability risks. IRS requires 15% FIRPTA withholding on property sales by non-US persons Buying via an LLC or C-Corp helps shield personal wealth from lawsuits HMRC taxes foreign property income and gains — with treaty relief possible Context: Who This Applies To This guidance is for US-based Realtors representing British clients purchasing or selling US real estate. These clients are typically: UK investors diversifying into Florida, Texas, or Arizona rentals British expats relocating to the US for work or retirement Dual-citizens managing homes in both the UK and US Why Legal Structure Matters In the US, litigation is common. Realtors advising foreign buyers mus...

  Reduce double taxation, stop PFIC surprises, and align UK pensions and US filings—without losing client control. US CPAs, EAs, and fiduciary advisors want to keep British-origin clients—but UK pensions, ISAs, and rental income create timing and reporting traps that risk penalties and erode trust. UK/US timing mismatches, PFIC filings, and new residence-based IHT rules are easy to misapply. You worry about “missing something UK-specific” that costs clients money. British clients deserve advice that respects both tax systems—without duplication. Optimise Accountants works behind the scenes with US advisors. Led by Simon Misiewicz FCCA ATT EA MBA, we align HMRC and IRS positions so you lead with confidence. Plan / Roadmap Discovery call (your client stays yours). Dual-jurisdiction map: income, timing, and treaty positions. Documentation pack: elections, forms, reconciliations. Quarterly check-ins; annual filing support. Rules & What Changed (2025) Remittance basis...

  Watch the video Summary American clients in the UK face a maze of HMRC/IRS rules. HMRC’s March 2024 update to INTM163160 tightened treatment of pension lump sums for US residents. PFIC rules make ISAs, OEICs and VCTs hazardous. This post outlines practical steps for UK wealth managers to reduce tax drag, avoid penalties, and safeguard client outcomes. Who this applies to UK wealth managers, IFAs, and accountants advising US citizens/green card holders in the UK, UK nationals moving to or investing in the US, and family offices coordinating dual filings. Why this matters now HMRC’s compliance yield rose 22.7% to £4.1bn in 2023–24, and offshore enforcement has recovered £3.2bn+ since 2010. FATCA/CRS data sharing means US/UK authorities already see the accounts—mistakes are rarely invisible. Key cross-border friction points Pensions and INTM163160 (Mar 2024): Clarifies how lump-sum pension benefits can be taxed when the recipient is US-resident. PFIC exposure: Most UK fund...