US Citizen - UK Ltd Company - Disregarded entity?

[US Cookie]

For a contract to be outside IR35 there a few items that need to be correct.
I'll not talk about all of them though.

If you are not sure whether to go self-employed or LTD then you have not had a contract offered yet. An contract is offered to a person or a company, so until you have decided you can't have an offer.
Without that contract you cannot determine any IR35 decision.

The next contract is with a client I've worked with before on a self-employed basis (a couple of years ago) and they were amenable when I said I wanted to use a limited company for this project. They will have external counsel review the contract prior to signing to ensure it falls outside IR35.

But I was looking at this article wrt IR35 and it seems that the project terms we've already verbally agreed meet all of these points (not sure about the substitution point).
IR35 contract risks: what to be wary of when signing contracts

[US Cookie]

I didn’t realise there were other American citizens on the forum. I’m really curious about your investments strategies and if you’ve been able to open accounts with brokerages here and buy US domiciled ETFs etc. Might need a different thread...

Will be very glad to discuss investment strategies on a different thread, as this is a topic I'm very interested in. I have some rental properties in the States which generate a small income, have thought about buying more in the future.

Also curious to know whether anyone has found an expat/worldwide health insurance policy which meets HSA rules?

[US Cookie]

Are you aware that capital gains on US funds, in the year they are realised, may be taxed as ordinary income to UK residents? Your taxable brokerage accounts in the US may be storing up a UK tax hit for you.

Also, you don't have to be limited to ETFs within a SIPP, as far as I am aware.

I wasn't aware of that at all! Thank you for pointing it out....that is something I need to look into. I was under the assumption that if I'm UK resident non-domiciled, I would not be taxed on US income that I never bring onshore to the UK.

[arby]

I was under the assumption that if I'm UK resident non-domiciled, I would not be taxed on US income that I never bring onshore to the UK.

This is no longer the case for quite some years now.

[CloudTyper]

"David" accountant website

I have searched but can't find contact information for "David" the accountant.

Can someone please post his website or a way to reach him?

Thanks!

Yes - he was the most helpful person I spoke to and clearly very knowledgeable. The conversation we had gave me much assurance. Although I've done my US taxes myself these last few years, I'll most likely hire him to prepare 2020 for me, because I don't want to get anything wrong, and I definitely don't want to take any chances paying someone else to get them wrong.

[WordIsBond]

I have searched but can't find contact information for "David" the accountant.

Can someone please post his website or a way to reach him?

Thanks!

David Treitel.

American Tax Returns - US and UK Tax Experts Tel: 020 8946 0523

[StressedOutCitizen]

Help!

I have finally spoken to someone who is mentioned on this and other sites as a highly regarded tax advisor for US/UK issues and he has confirmed that I can indeed file as a disregarded entity and therefore would not have a CFC

Hi, I'm in EXACTLY the same situation as you. I'm a property investor and am just setting up a UK Ltd company. I've spoken with a dual citizen accountancy company who are VERY knowledgeable and can definitely give me the advice I need moving forward to guide me throughout my ventures. However, they also charge 3 to 4 times more than my current dual citizen accountant for just the US and UK tax filing which is seriously ridiculous.

My existing accountant and this other expensive accountant are both based in the UK. My existing accountant is seemingly not as well versed as this other company I've found and is much more difficult to get in touch with in a timely manner. Wondering who you are using and if you would kindly pass me their information? I desperately need someone who is not only knowledgeable but affordable also....

Many thanks!

[US Cookie]

Hi, I'm in EXACTLY the same situation as you. I'm a property investor and am just setting up a UK Ltd company. I've spoken with a dual citizen accountancy company who are VERY knowledgeable and can definitely give me the advice I need moving forward to guide me throughout my ventures. However, they also charge 3 to 4 times more than my current dual citizen accountant for just the US and UK tax filing which is seriously ridiculous.

My existing accountant and this other expensive accountant are both based in the UK. My existing accountant is seemingly not as well versed as this other company I've found and is much more difficult to get in touch with in a timely manner. Wondering who you are using and if you would kindly pass me their information? I desperately need someone who is not only knowledgeable but affordable also....

Many thanks!

The person I referred to is David Treitel - the same person mentioned above. He has not completed a tax return for me yet because my 2020 tax return will be the first time I need this assistance. So I don't know what his fees are, but maybe one of the other people on this forum could give you an idea of the range.

American Tax Returns - US and UK Tax Experts Tel: 020 8946 0523