Question: Hi, I am non domiciled and currently claiming offshore income exemption on a remittance basis. I have recently opened a online stock trading account with Interactive Brokers UK. The account allows me to trade stocks in many different countries and allows me to hold cash in many different currencies as well. Interactive Brokers UK is actually the UK subsidiary of the US-based Interactive Brokers LLC as stock brokers need to have a local FSA regulated entity in order to market stock dealing services to UK residents. The account was funded with US dollars paid from a Guernsey account to the a Citibank NY account in the name of Interactive Brokers LLC (US). The account is used to hold only US stocks. The account has generated income from the interest earned on the US dollar cash eventually held and from dividends paid by the US stocks. I also had capital gains and losses that resulted from the purchases and sales of US stocks. The account never held sterling and/or UK stocks and it never made a transfer to a UK bank account. The questions are: 1) Can the US stocks and the US dollar cash be treated as offshore assets for the purpose of remittance basis taxation? All the custody of these assets is clearly held in the US by IB LLC, but when I print a statement, for instance, it is headed by IB (UK), as they are the entity with whom the account was opened. 2) Should the transfer of US dollars cash, from the Guernsey account, to the IB LLC US account, be considered a remittance to UK? (again, because the "front-end" of the account is IB UK). . . . (to read the remainder of this article, please log in below.)
The resource you have requested is available only to current members.
If you are a current member, log in using the form below.
If you are not a member, we invite you to view the subscriber benefits at Membership Benefits Forgotten Password? If you are a current member and have forgotten your password, enter your email address below, and your password will be emailed to you.
Tax changes in the Emergency Budget Well, the Emergency Budget has now come and gone. There have been a number of tax changes, however its fair to say he hasn't gone as far as many people thought . . . keep reading
Moving abroad to avoid the 50% rate of income tax The highest 'official' rate of income tax has increased to 50% as from 6 April 2010 (although there is a 60% effective income tax rate on income between £110K-£113K). In this article we assess how moving abroad can allow you to avoid the new 50% rate of income tax . . . keep reading
Financial trader or investor after the 22 June Emergency Budget? Most financial investors could be paying CGT at 40% or potentially 50% from next year. This certainly narrows the gap between trader and investor status, and in this article we look at how the change in the rate of CGT will make trader status more attractive. We also include a schedule showing the likely taxes payable for different profit levels under the new rules. . . . keep reading
at 'YourTradingEdge' magazine and the author of 'The Investors Tax Bible'
Using a company will be even more attractive for property and financial investors after the increases in the Emergency Budget
Tax changes in the Emergency Budget
Moving abroad to avoid the 50% rate of income tax
Offshore bonds now more attractive after CGT and income tax changes
Financial trader or investor after the 22 June Emergency Budget?