Client is a US citizen but has lived in UK for many years and done UK tax returns as well as his US tax returns.
Because he has paid a lot more tax in the UK than he would have in the US on his income he has advised he has a large credit on his US tax account.
Not sure how this operates or what it means as I have not handled this type of situation before. He will continue to live in UK for forseeable future but wants to buy a property in US to rent out to use up his US tax credits to set against this rental income. He doesn't believe he will have any tax to pay in the US because of these brought forward credits in the US but I don't know how this would interface with the UK tax system which taxes worldwide income in the UK.
Could someone give a bit of guidance about how this might work between the 2 countries and whether he is likely to be taxed in UK even though he may not have tax to pay in US? I am sure there are rules within the DTT but not sure of basic principles involved.
May be one I have to pass on.