USA Double tax relief

USA Double tax relief - federal versus state tax

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May I just check that the effect of the DTA between US & UK means that only the federal tax is available for foreign tax credit relief for a UK resident tax payer?

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By Marion Hayes
11th Aug 2016 17:30

I suggest you pm David Treitel if you need assistance with American tax. I haven't seen him posting since the changes but I am sure he wouldn't mind.

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By User deleted
11th Aug 2016 17:53

Your understanding is correct

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By nick farrow
12th Aug 2016 09:46

Thanks Marion & Guru - I have spoken to David before over a more complex area and he was very helpful

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By David Treitel
12th Aug 2016 19:51

While you are correct that the Treaty is only effective for Federal purposes; my understanding is that HMRC are quite content to offer unilateral relief for State tax. HMRC lists in its Double Taxation Relief Manual at sections DT19855 to DT19855C the admissible and inadmissible state taxes for such relief.

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