Readers Forum: Double trouble?

I act for a husband-and-wife team that conducts a business through a UK incorporated company. The individuals are US citizens but have been resident in the UK for tax purposes for several years.

It should be noted that because the company does not have any presence in the US such as an office or an agent solely representing it a view has been taken that it cannot be construed as having a permanent establishment in the US. Consequently the dividends paid by the UK company to the individuals by virtue of the double taxation treaty between the UK and US are only taxable in the country of residence which is the UK. The UK/USA Double Tax Convention Art 10 para 6 and the explanations of those provisions that accompany the treaty appear to make the position clear.

I have completed US tax...