Trust which is UK and US tax resident

I act for a trust which has a sole UK resident individual trustee - so the trust is UK tax resident for UK tax purposes. It is not a bare trust. The trust is a US trust (irrevocable). I’ve been told that the trust pays tax in the US as a standalone entity. The trust is planning on selling its share portfolio - so CGT in the UK assessable on the trust. I’ve been told the trust will also pay tax in the US on the sale at a similar rate. Does anyone have any thoughts in terms of foreign tax credits?

Hi Katy

If you are not already taking specialist advice on your US reporting requirements for this trust I suggest you do so now.

With best wishes


Sara Spencer ATII TEP | Trust Manager

Sara Spencer Ltd, 8 Kingsway, Harrogate, HG1 5NQ

07952 651881 | 01423 524114

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