My client worked in the USA for Warner Lambert and paid into a savings plan. From September 1990 until August 1993 he paid in a monthly amount which was matched to varying degrees by his employer. When Pfizer bought the company the savings plan was transferred to the Pfizer savings plan and the investment was all in Pfizer stock.
The funds were transferred to the UK in May 2013 and the client signed a form so that no American taxes were deducted.
I have no idea how to treat this. Any suggestions?
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Sounds like an ESPP to me. The employee bought stock in his employer with an employer match. The stock was sold, so you need to calculate the gain or loss for UK purposes using spot exchange rates for each date of purchase and sale throughout the life of the plan.
Unless your client is electing to claim the remittance basis, bringing the proceeds to the UK is not relevant to UK tax.
If your client is not a US citizen or green card holder and was not subject to backup withholding and signed a W-8BEN the broker will not have withheld US tax on dividends (including any reinvested during the life of the plan) or proceeds.
From a UK perspective one would claim typically exemption on a UK personal tax return under Article 17(2). If UK tax relief had been claimed at some point past on contributions there might still be a chance of an unauthorised payment charge.
From a US perspective, the individual will be required to file a tax return (Form 1040 or Form 1040NR depending on residence status) for 2014 and will be subject to US tax at graduated US income rates on all of the growth and at least on all of the contributions to the extent that the contributions related to service in the United States.
It seems imprudent for your client to have asked for no withholding when the payment was made to him, as there will be a good sized liability to be paid to the IRS no later than 15 April 2015. Your client may wish to pay most of this sooner as an estimated payment, to minimise the penalty for underpayment of estimated tax for 2014.