Here's my situation:
- I have lived and worked in Hong Kong for the last 3.5 years, running a limited company as sole employee, IT contracting to various clients. Nice simple tax legislation here thankfully
- I previously lived all my life and was tax resident in the UK until 2005 when I moved to HK. I am currently non-resident from UK tax perspective.
- I will move back to the UK into my old house on 1st May 2009 and originally planned to become UK tax resident from that date forward (split year treatment protecting the last of my Hong Kong income - i.e. upto end April - from UK tax).
- Am now (unexpectedly) negotiating an 8-month contract with a US company which would see me work 3 weeks out of every 4 in the US and the other week work remotely from my home in the UK. As far as the 2009 US tax year goes, I estimate I will do <183 days so believe I have the ability to remain a non-resident alien from a US perspective although this might be complicated by the timing of the contract start (possibly 30th March) and my current residence in Hong Kong.
- The US company prefers me to work through one of their established third-party payroll agencies in the US although I could insist on a different structure if required - including a foreign entity. I only have the Hong Kong company at this time and have never contracted in the UK.
- The US company prefers to pay me a blended daily rate inclusive of my travel and living expenses in the US and I'm concerned about whether I will be able to file deductions for my actual expenses (with HMRC and/or the IRS).
Optimising my tax is clearly a major goal, but my priority right now is understanding the legal and tax implications so that I can structure a contract and agree a rate knowing what tax I will have to pay.
As you can see, my situation is quite complex and I would really appreciate advice from someone who has been through a similar personal experience (at least in terms of the US/ UK setup) and/or recommendations of advisory firms that have the required international tax planning experience.
TIA
Phil
- I have lived and worked in Hong Kong for the last 3.5 years, running a limited company as sole employee, IT contracting to various clients. Nice simple tax legislation here thankfully
- I previously lived all my life and was tax resident in the UK until 2005 when I moved to HK. I am currently non-resident from UK tax perspective.
- I will move back to the UK into my old house on 1st May 2009 and originally planned to become UK tax resident from that date forward (split year treatment protecting the last of my Hong Kong income - i.e. upto end April - from UK tax).
- Am now (unexpectedly) negotiating an 8-month contract with a US company which would see me work 3 weeks out of every 4 in the US and the other week work remotely from my home in the UK. As far as the 2009 US tax year goes, I estimate I will do <183 days so believe I have the ability to remain a non-resident alien from a US perspective although this might be complicated by the timing of the contract start (possibly 30th March) and my current residence in Hong Kong.
- The US company prefers me to work through one of their established third-party payroll agencies in the US although I could insist on a different structure if required - including a foreign entity. I only have the Hong Kong company at this time and have never contracted in the UK.
- The US company prefers to pay me a blended daily rate inclusive of my travel and living expenses in the US and I'm concerned about whether I will be able to file deductions for my actual expenses (with HMRC and/or the IRS).
Optimising my tax is clearly a major goal, but my priority right now is understanding the legal and tax implications so that I can structure a contract and agree a rate knowing what tax I will have to pay.
As you can see, my situation is quite complex and I would really appreciate advice from someone who has been through a similar personal experience (at least in terms of the US/ UK setup) and/or recommendations of advisory firms that have the required international tax planning experience.
TIA
Phil
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