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18 January 2011
A US citizen who has lived in the UK for two years is the beneficiary of a US grantor trust and a US non-grantor trust
I have a client who is a US citizen and has been living in the UK for more than two years.
He is a non-UK domicile with a US grantor trust and also US non-grantor trust.
Sometimes he is in receipt of income from both trusts but there have been years that he has not been. My questions are as follows.
- How is the US grantor trust treated as a UK resident but filing on a remittance basis?
- How is the US non-grantor trust treated as a UK resident but filing on a remittance basis?
- How is the US grantor trust treated as a UK resident if filing on an arising basis?
- How is the US non-grantor trust treated as a UK resident if filing on an arising basis?
If he is not in receipt of income...
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