Case Studies

Challenge

An American who had lived in the UK for over ten years had never filed US returns or FBARs after moving, assuming UK tax was the end of the story. A letter from her bank citing FATCA made the exposure impossible to ignore.

Solution

We confirmed her eligibility for the IRS Streamlined Foreign Offshore Procedures, prepared three years of delinquent returns and six years of FBARs, and used foreign tax credits for UK tax already paid to offset the US liability.

Results

• Accepted into the Streamlined Foreign Offshore Procedures with no failure-to-file penalties
• UK tax already paid absorbed almost the entire US liability through foreign tax credits
• A clean baseline and a coordinated US/UK filing calendar going forward

Challenge

A US person investing through UK unit trusts and a stocks-and-shares ISA had unknowingly built a portfolio of PFICs, exposing every gain and distribution to punitive US excess-distribution rules and Form 8621 reporting.

Solution

We identified every PFIC across the accounts, modelled the US cost of each exit route, sequenced disposals to keep both US and UK gains manageable, and rebuilt the portfolio around US-friendly holdings.

Results

• Every PFIC identified and reported correctly on Form 8621 before the IRS raised it
• Disposals sequenced so US and UK capital gains stayed coordinated rather than colliding
• A rebuilt portfolio that no longer generates punitive PFIC treatment each year

Challenge

A growing US company hiring its first UK employees faced questions it had never met at home: permanent establishment risk, UK corporation tax and VAT registration, payroll in two systems, and how the US parent should own the UK operation.

Solution

We structured a UK subsidiary with clear intercompany arrangements, registered it for corporation tax, VAT, and PAYE, and coordinated the US and UK filings so the group's position was consistent in both countries from day one.

Results

• UK subsidiary structured and registered with corporation tax, VAT, and PAYE in place before launch
• Permanent establishment exposure for the US parent contained by design
• One coordinated group position across IRS and HMRC filings

Challenge

A couple with US 401(k)s and IRAs on one side and UK workplace pensions and a SIPP on the other faced conflicting rules on contributions, growth, and withdrawals, including the risk that the 25% UK tax-free lump sum would be fully taxable in the US.

Solution

We applied the US-UK tax treaty's pension articles to each pot, timed withdrawals against residence and both countries' tax years, and documented every treaty position so each payment was taxed once, in the right country.

Results

• Each pension taxed once under the treaty, with positions documented for both authorities
• Withdrawal timing aligned to both tax years to avoid double-tax windows
• A retirement income plan the couple can follow in either country

Challenge

A British executive moving to New York carried unvested RSUs granted in London, a UK rental property, and a SIPP. The US was set to tax income the UK also claimed, and state tax added a third layer.

Solution

We planned the residence transition across both systems, apportioned the equity income between the UK and US under the treaty, kept the UK property compliant through the non-resident landlord scheme, and set up correct US reporting for the SIPP.

Results

• Equity income apportioned between the UK and US so no tranche was taxed twice
• UK rental income kept compliant on both sides, with credits applied correctly
• SIPP reported properly in the US from year one, avoiding retroactive cleanup

Challenge

Born in the US but raised entirely in the UK, she learned of her US filing obligations only when her bank requested a W-9. She wanted to weigh full compliance against renouncing citizenship, without triggering exit tax surprises.

Solution

We brought her current through the Streamlined Foreign Offshore Procedures, quantified what continued citizenship would cost each year, and mapped the expatriation rules so a future renunciation decision would be informed rather than forced.

Results

• Full US compliance achieved through the streamlined procedures without penalties
• Clear annual cost of retaining citizenship, quantified for an informed decision
• A documented path to renunciation that avoids covered-expatriate status