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A US national is the beneficiary of a portfolio of US-based investments and trusts. She is resident in the UK and, for some years, has received US rental income from a property that is now being sold at a substantial capital gain
My client Ms A is a US national. In 1992 she came to the UK with her husband who was born in the UK. Her children were also born in the UK.
On the death of her parents Ms A became a beneficiary of a portfolio of US-based investments and US trusts etc and for the past two years she has received US rental income.
This has been disclosed in the UK return and a deduction has been made for both federal and New York state taxes.
The property is now in the process of being sold for a substantial sum.
We have calculated that there is a UK capital gain but that the offset of federal and state taxes will reduce the tax chargeable to nil.
However I have read some correspondence between my client and her US advisers and I now have...
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