This unique book is a concise but complete tax planning manual for those advising high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members.
Guide to US/UK Private Wealth Tax Planning covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with:
A quick reference summary of the UK and US rules applicable to your clients;
A comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US;
Optimal income and gains tax planning for foreign trusts with UK or US beneficiaries;
Integrated UK and US tax planning solutions for clients exposed to both UK and US tax.
Previous edition ISBN: 9781845920272
Withers LLP is the leading law firm for private client, tax and trust advice in Europe, the US and Asia. Robert L Williams is a US international tax attorney and former EY international tax partner.
Part I: Outline of Relevant Taxes Section 1: Principal taxes Chapter 1 Taxation status in the US: overview Chapter 2 US: transfer tax system Chapter 3 US: transfer taxes: marital deduction Chapter 4 US: state death and inheritance taxes Chapter 5 US: tax on capital gains Chapter 6 US: tax basis rules for gifts and bequests Chapter 7 US: income tax Chapter 8 Overview of principal UK taxes Chapter 9 UK: inheritance tax on individuals Chapter 10 UK: pre-owned asset tax Chapter 11 UK: income tax Chapter 12 UK: capital gains tax Chapter 13 UK: the arising basis and the remittance basis Chapter 14 UK: corporation tax Chapter 15 UK: annual tax on enveloped dwellings Chapter 16 UK: stamp duty land tax Section 2: Tax status and basis of taxation Chapter 17 US: citizenship Chapter 18 US expatriation Chapter 19 US: income tax residence rules for foreign nationals Chapter 20 US: trust residence (income tax) Chapter 21 US: income taxation of non-resident aliens and foreign corporations Chapter 22 US: domicile and transfer taxation of non domiciliaries Chapter 23 US: situs of assets taxable to non domiciliaries Chapter 24 Taxation status in the UK: overview Chapter 25 UK nationality Chapter 26 UK: domicile Chapter 27 UK: residence of individuals Chapter 28 UK: residence of trustees Chapter 29 UK: residence of companies Chapter 30 UK: situs Section 3: Trust and estate taxation Chapter 31 US: transfer taxes on trusts Chapter 32 US: grantor trusts Chapter 33 US: non-grantor trusts Chapter 34 US: special needs trusts Chapter 35 US: intentionally defective grantor trusts Chapter 36 Crummey Powers Chapter 37 US: qualified personal residence trust Chapter 38 US: taxation of deceased's estates and beneficiaries Chapter 39 GRATs Chapter 40 UK: inheritance tax on trustees Chapter 41 UK: trusts - income tax and capital gains tax Chapter 42 UK taxation of personal representatives Section 4: Taxation on corporations Chapter 43 US and Treaty entity classification rules - corporations, partnerships and branches Chapter 44 US: private trust companies Chapter 45 US: passive foreign investment companies Chapter 46 US: controlled foreign corporations Chapter 47 US: partnership interests of non-US persons Chapter 48 US: non-US corporations and estate tax Chapter 49 US: treatment of non-US entities Chapter 50 UK: UK tax classification of non-UK entities Chapter 51 UK: companies Chapter 52 UK controlled foreign companies Chapter 53 UK: partnerships Chapter 54 UK: offshore funds and offshore income gains Section 5: Charities Chapter 55 US charities Chapter 56 UK: taxation of gifts to charity Section 6: Insurance Chapter 57 US: life insurance policies Chapter 58 UK: qualifying and non-qualifying insurance policies Chapter 59 UK: personal portfolio bonds Section 7: Compliance Chapter 60 US compliance: 12 foreign tax reporting forms Chapter 61 US: withholding tax regulations Chapter 62 US FATCA Chapter 63 US requirement for reporting of foreign financial accounts FBAR and tax FBAR annual reports Chapter 64 US offshore voluntary disclosure program Chapter 65 US foreign trusts' reporting requirements Chapter 66 UK: self assessment Chapter 67 UK: trust reporting Chapter 68 UK: tax information exchange measures Chapter 69 UK: general anti-avoidance legislation Section 8: US-UK Treaties Chapter 70 The US-UK Income Tax Treaty Chapter 71 The US/UK estate and gift tax treaty Part II: Planning Chapter 72 UK: pre-immigration planning Chapter 73 US: pre-immigration planning Chapter 74 Expatriation Chapter 75 Lifetime giving Chapter 76A Spouses and civil partners: lifetime planning Chapter 76B Spouses and civil partners: testamentary planning Chapter 76C Spouses and civil partners: jointly-owned property Chapter 76D Divorce planning Chapter 77 Insurance planning Chapter 78 Trusts and partnership planning: forming trusts and other entities Chapter 79 Trusts and partnership planning: planning with existing trusts Chapter 80 Wills Chapter 81 Probate and the administration of estates: tax issues for personal representatives Chapter 82 Post-death variations and disclaimers Chapter 83 Giving to charity Appendix I: US Tax Tables 2016/2017 Appendix II: UK Tax Tables 2016/17 Appendix III: 2001 United Kingdom-United States Income Tax Treaty (conformed to include the 2002 Protocol) Appendix IV: 1978 United Kingdom-United States Estate and Gift Tax Treaty Appendix V: The American Diaspora, Innocents Abroad Appendix VI: FATCA, IGAs, and the OECD CRS: The Future Landscape for Trusts Appendix VII: Trust and Company Strategies to Avoid Penal US Tax Exposures.