UK/US outbound investment
US individuals acquiring investments outside of the US face a broad range of special rules designed to mitigate the potential tax benefits as well as to provide the US IRS with information about the investments. These rules can result in significant tax leakage and a failure to fully comply with reporting requirements can lead to heavy penalties.
UK-based individuals are likewise subject to equivalent UK rules governing offshore investments and structures.
We can assist by advising on the consequences of overseas investments before they are acquired, as well as the associated reporting requirements. We can also review existing portfolios. We have significant experience reviewing all types of investment and we can recommend appropriate pre-emptive action or structuring in order to minimise adverse tax leakage.
Where investments are also subject to both UK and US tax (or tax in another country), we can advise on the interaction of both systems and identify any potential tax mismatches which may cause double taxation.