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Double taxation

23 July 2013
Issue: 4412 / Categories: Forum & Feedback , Double taxation , Residence & domicile

A US green card holder returned to live in the UK some years ago and received occupational and state pensions from the US. She also receives a UK pension which seems to be subject to US tax

Our client now deceased was a US green card holder but returned to the UK several years before her death. She had not filed any tax returns in the US or the UK. The green card had not been surrendered on a timely basis so the advice from a US accountant was that “normal” US tax returns would have to be filed which he has done.

Our client was in receipt of both US occupational and US state pensions which have been taxed in the US. No reduction in the assessable amounts has been given in the US although on another US client it appears that less than the full amount of the state pension is assessable.

The double taxation agreement appears to give first taxing rights to the UK where we have taken the 10% deduction for a foreign pension but we...

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