# US/UK Tax & Financial Advice



## Chick (May 15, 2008)

Hi! I'm seeking a tax accountant in London specialising in US and UK tax; I've used the same firm for a number of years but the cost has become outrageous. Does anyone have someone they're happy to recommend? Thanks for your help!


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## Bevdeforges (Nov 16, 2007)

I'm a CPA myself (living in France) and I have found that it's pretty difficult to find a single accountant anywhere to handle both US and UK (or any other country) taxes. The best placed are the big public accounting firms, because at least those guys have associates back in the US to confer with. But, as you have noticed, their prices are outrageous.

You might try asking around some of the US expat groups in the London area. Many times they have a member or sponsor who does US and UK taxes - either a tax attorney, a tax accountant or an enrolled agent.
Cheers,
Bev


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## Chick (May 15, 2008)

Thank you!


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## boyojohnquinn (Oct 14, 2008)

*Hey*

Yeah I had to look for them for a while until a mate put me on to these guys: Tax Advisory Partnership

they can do both.

regards,
John


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## Bevdeforges (Nov 16, 2007)

You may want to look into using an enrolled agent - there's a locator here: https://portal.naeacentral.org/webportal/buyersguide/professionalsearch.aspx?Token=

Enrolled agents are certified by the IRS for doing US taxes, but there are several in the UK and they may have further qualifications in UK taxes. Depending on how elaborate your tax situation is, you may get as good or better tax assistance from an EA, and at a significantly lower price. (An online friend of mine is an enrolled agent in San Francisco and I know she does very good work.)
Cheers,
Bev


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## esteban (Jul 17, 2009)

Chick said:


> Hi! I'm seeking a tax accountant in London specialising in US and UK tax; I've used the same firm for a number of years but the cost has become outrageous. Does anyone have someone they're happy to recommend? Thanks for your help!


yes,prices are more than i've ever seen.
my current$$$$$$$$ is buzacott.
what's yours?


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## Chick (May 15, 2008)

*Buzzacott*



esteban said:


> yes,prices are more than i've ever seen.
> my current$$$$$$$$ is buzacott.
> what's yours?


Yes, I was using Buzzacott - they're the ones I thought expensive. They're pretty good but the fees went up every year. I'm now trying US Tax...not satisfied yet but, as a mid-sized firm, probably a bit cheaper than the big boys (but not a lot!).


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## Punktlich2 (Apr 30, 2009)

esteban said:


> yes,prices are more than i've ever seen.
> my current$$$$$$$$ is buzacott.
> what's yours?


What kind of prices are being charged? There are a couple of retired IRS accountants in London I have met and who are said to be very reasonable because they work out of home. 

I use tax software and have never seen it necessary to hire anyone, and I do expatraigte friends' returns too. But although qualified and licensed I have never done work for the general public and wouldn't know what to charge if I did.


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## Chick (May 15, 2008)

Punktlich2 said:


> What kind of prices are being charged? There are a couple of retired IRS accountants in London I have met and who are said to be very reasonable because they work out of home.
> 
> I use tax software and have never seen it necessary to hire anyone, and I do expatraigte friends' returns too. But although qualified and licensed I have never done work for the general public and wouldn't know what to charge if I did.


The specialists such as Buzzacott and US Tax charge a range "up to" £1200 for a US return, although it can be more when there were additional forms such as rental income, depreciation, self-employment, etc. I've experienced a range of hourly rates for certified accountants who specialise in US taxes from £275 to £350 an hour, so any questions, advice, etc., beyond the return also add more cost. In addition, most expats want the same person or firm doing both US and UK returns. If you're not offering it now, it's potentially a lucrative area. However, having had a bad experience with one "lone ranger", I'm sticking to companies that have more than one person I can rely on!


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## Punktlich2 (Apr 30, 2009)

Chick said:


> The specialists such as Buzzacott and US Tax charge a range "up to" £1200 for a US return, although it can be more when there were additional forms such as rental income, depreciation, self-employment, etc. I've experienced a range of hourly rates for certified accountants who specialise in US taxes from £275 to £350 an hour, so any questions, advice, etc., beyond the return also add more cost. In addition, most expats want the same person or firm doing both US and UK returns. If you're not offering it now, it's potentially a lucrative area. However, having had a bad experience with one "lone ranger", I'm sticking to companies that have more than one person I can rely on!


Those are quite incredible prices, thanks for the info. I do individual, partnership and corporate returns for the US, UK, Canada and Switzerland but, as I said, only for extended family and acquaintances. I am not soliciting business, and anyway I'm not a tax accountant but a tax lawyer: I write on this stuff and practice to the extent needed to know the issues practitioners face.

I know that mass layoffs in the City of London and the end of employer-paid tax returns done by the Big 4 have left many brokers and traders who chose to stay in London adrift. I had a chat with a head hunter a few weeks ago; she said that she has a new client who undercuts the big boys and is hiring to expand their practice, but I forgot the name.

As a lawyer, albeit one who rarely sees the inside of a court unless I'm tagging along with my barrister daughter, I am aware of a great deal of malpractice in this area, more's the pity. Mostly the client never finds out. 

Similarly with wills and trusts, and investments too. Mostly people never get caught out, but the potential traps between the US and the UK (the latter now that long-term residents don't get non-dom benefits in most cases) promise to give rise to real hardship. Who knows about the taxation -- in effect double taxation -- of trust accumulations and mutual fund/unit trust earnings? Who thinks to ask about all those reporting forms for the IRS and Treasury: 3520, 5471, TD F 90-22.1? The penalty for not filing a 5471 is $10,000. 

What are "accidental Americans" who have never lived in the USA and who live on modest self-employment earnings or have small businesses to do? The IRS admits in its literature that the penalties for nonreporting can grossly exceed the value of assets. And one can never discharge them in a US bankruptcy. (Under the principle of the Lord Mansfield dictum the UK will not enforce such foreign taxes penalties in its courts. but recent models of tax treaties make certain exceptions to that ancient "rule".

I have graduate law degrees from three countries and sometimes the rules are indecipherable to me and to my university colleagues. It's my opinion that the IRS quite enjoys being in the position of that French bureaucrat who, with a tight smile, tells you, "Monsieur, vous êtes en situation irréguilère", knowing you are now at his mercy.

Fortunately most expat tax returns are in fact trivial, which is why £1,200 is a bizarre amount to charge. But estate planning is not: what is one to do about a QDOT when the result of placing the family residence in a foreign trust would potentially be -- stamp duty aside -- an annual charge on shadow director income based on rental value and onerous UK taxation of the foreign trust itself. But a UK court wouldn't enforce the QDOT law, and many widow(er)s are better off abandoning US assets, or else evading US tax and never visiting the US or Canada (under the current treaty Canada enforces some US tax laws).

The US distrusts, and some would say despises, "foreignness". Perhaps it's the War of 1812 fought over perpetual allegiance all over again. The UK, with hastily and carelessly drawn legislation has made things worse for expats.

Fortunately though, most expats will stay below the radar. In looking at the returns of others I find that most mistakes never get found out, and that is true whether the errors result in too much tax or too little.

Finally, read this: http://www.emailthis.clickability.com/et/emailThis?clickMap=viewThis&etMailToID=402687364 (WSJ.com - IRS Gets Tougher on Offshore Tax Evaders) The link should be valid for seven days.


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## Bevdeforges (Nov 16, 2007)

Hi Punktlich2,
You make lots of excellent points in your post. I come at the issue from the other side - I'm an accountant, a CPA in the US with some experience in and with the big public accounting firms. Unfortunately, there really aren't all that many hands-on practitioners who truly understand both (or all) sides of the multi-national tax situation.

As far as the US is concerned, there is also a certain level of "what the IRS will and won't bother with." Within the big accounting firms, there are lists of items that constitute "red flags" and will make a client's return more likely to audit or intense review. The IRS is said to have a similar list, complete with point values, which they use when determining which returns to audit - though they deny this vehemently, or simply refuse to disclose any such lists.

Similarly, the IRS is well aware that the vast majority (or so I suspect) of US citizens (accidental or otherwise) living overseas probably aren't filing returns. As long as they "probably" fall under the earned income exclusion, they simply don't bother trying to find them - hence the long-standing policy of forgiving past sins if an expat files 3 years in arrears showing no tax liability. OTOH, if someone living overseas has enough income and assets to be concerned about estate planning, that's probably someone the IRS is more interested in "getting to know." (And I've been told that in the matter of sharing estate tax returns, the US is particularly cozy with their European tax counterparts.)
Cheers,
Bev


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## Punktlich2 (Apr 30, 2009)

Bevdeforges said:


> Hi Punktlich2,
> You make lots of excellent points in your post. I come at the issue from the other side - I'm an accountant, a CPA in the US with some experience in and with the big public accounting firms. Unfortunately, there really aren't all that many hands-on practitioners who truly understand both (or all) sides of the multi-national tax situation.
> 
> As far as the US is concerned, there is also a certain level of "what the IRS will and won't bother with." Within the big accounting firms, there are lists of items that constitute "red flags" and will make a client's return more likely to audit or intense review. The IRS is said to have a similar list, complete with point values, which they use when determining which returns to audit - though they deny this vehemently, or simply refuse to disclose any such lists.
> ...


That "coziness" is subject to lots of conditions. For example, the Canada-US Protocol which goes further than any other US treaty in terms of mutual enforcement of tax claims, excludes citizens of the target (requested) government. Few, probably almost no, countries will assist a foreign country in a tax claim not involving money-laundering or drugs or fraud where the (non-)taxpayer is also (or only) a citizen of the requested country. The UK has a generous extradition treaty with the US and it is said that many accused persons have been unfairly extradited by the UK to the US. But as with the European Arrest Warrant, tax crimes are excluded.

I don't think the IRS will get far in seeking to enforce US estate duty in lieu of a QDOT against a British widow. There are many unfortunate/outrageous situations in income taxation too, some of which yield tax over 100%. In the Carter years when foreign earned income exclusion was abrogated, US schoolteachers in Nigeria earned, say, $25,000 in cash, plus an apartment and car that due to the overvalued exchange rate led to tax over 100%. The IRS guy in Paris told me they really hoped such cases would not come to their attention. Think also of the "beneficiaries" of incentive stock options who owed tax on phantom income after the stock tanked in the dot-com crash. Waiting out the SOL and then filing bankruptcy was the only solution after Congress failed to act.

In France the reliance on wealth taxes and social contributions means that most tax paid to the French Government is not creditable on Form 1116. My daughter's boss in Paris recently consulted me on surrendering his green card to end what amounted to a voluntary $50k annual payment to the USG. 

In estate cases, as I said, one can safely fashion a non-payment plan if (and perhaps only if) all assets and all heirs are outside the USA (and preferably also non-citizens).

On the nationality point: the US is one of those (few among OECD countries) that does not know who its citizens are. Many countries -- here in Switzerland, also Denmark, Belgium and other European countries -- withdraw the nationality of a child one s/he reaches majority or age 22 etc. abroad and fails to declare him/herself to a consulate and (obviously) has another nationality as well. 

By and large IRS wants six years of back returns, and no more. Years ago I had a client who was the spouse of a non-filer who, incredibly, was a USG auditor in Europe. When he died I advised her to file six years of back returns as married filing separately, and we also filed a minimum of self-employment income. There was at the time no totalization agreement with the country where she lived; the result was she got her survivor's civil service pension and a minimum social security plus Medicare. 

One ought not to plan on the basis of nonpayment of tax; but even the IRS had to deal cutely with those who had their US citizenship unexpectedly restored by the Supreme Court: Rev. Rul. 75-357, PLR 8138071 (accepted an attribute of US nationality; under international law it is unlawful to impose a nationality without consent on someone at a time other than birth or adoption or, perhaps, marriage), see Vance v. Terrazas, 444 U.S. 252 (1980 and 7 FAM 1250. Many, many persons are never documented in their lives as Amcits and because they never lived in the USA for 5 years, 2 of them after age 14, any offspring will not be Amcis unless the spouse is. (The rule is one year without ever leaving in respect of nonmarital offspring born abroad.)

It is no surprise to me that here in Switzerland the cantonal and private banks decided not to open, and if they had one to close, US offices. QI rules, and the EU savings agreement are one thing, invasive access to books and records quite another. I quite like the outcome in the Van deMark case, 68 O.R.(2d) 379 (Ont. H.C.J.) where the Toronto-Dominion Bank, from whose NYC branch disputed US taxes were seized from the depositor under the principle of transferee liability, had to pay the same amount to the Canadian depositor. The funds were, after all, deposited in one of the bank's Ontario branch.


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## Bevdeforges (Nov 16, 2007)

Ooh, we're really drifting here, but this is kind of interesting stuff - at least to the likes of you and me.

It's not always the US that is the heavy in these situations, either. I have been told by some of the tax lawyers here in Paris that failure to declare overseas bank accounts on your French returns can lead to the accounts being essentially impounded on your death rather than being passed along to heirs.

But again, that kind of depends on your having sufficient assets to draw the attention of the tax people from the various countries involved.

And, I must say that I have found the IRS folks in the Paris office to be genuinely helpful - something that is not always the case back on the IRS's home turf.

One big potential glitch in all this is the liberalization of the US citizenship laws - done back in the 1970's due to lobbying from US expats. We've now got a generation of US citizens of prime tax-paying age who have never lived in the US, but who have a US tax obligation (whether they realize it or not). The son of a friend of mine was in this position and was considering renouncing his US citizenship prior to starting his own company here in Europe. His mother was distraught at the idea of him renouncing, but I can certainly understand his motivation.
Cheers,
Bev


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## Punktlich2 (Apr 30, 2009)

Bevdeforges said:


> Ooh, we're really drifting here, but this is kind of interesting stuff - at least to the likes of you and me.
> 
> It's not always the US that is the heavy in these situations, either. I have been told by some of the tax lawyers here in Paris that failure to declare overseas bank accounts on your French returns can lead to the accounts being essentially impounded on your death rather than being passed along to heirs.
> 
> ...


Most IRS attachés abroad are being rewarded for good, loyal and quality service in what amounts to a pre-retirement post. Nothing wrong with that, and it tends to get us experienced, intelligent, non-"jobsworth" people in the position. They no longer have a "quota" or anyone they have to please to get a promotion.

The French cannot "impound" a foreign account. And in the French law of succession there is no disinterested "syndic" or executor or trustee: assets pass to the heirs as a matter of law (as does, through an anomaly, real estate in New York, whether or not there is a will). The anomaly here is that if the (non-)estate (i.e., the decedent) is insolvent the heirs have to disclaim or they inherit the debts! I heard once of a child who had to be made bankrupt because he had inherited an insolvent business (there is no personal bankruptcy in France, the Loi Neiertz is a 5-year standstill for overindebted consumers).

What the French can do is to reclaim inherited French assets to compensate for foreign assets that have escaped tax or "forced heirship". That's what was at issue in the succession of Leslie Caron's father: Caron v. Odell

But the issue is less important in France than it once was: wealthy French taxpayers have fled abroad, to Switzerland and other places. The fall in interest rates has made the tax on foreign savings interest trivial. 

The olden days when the 25-km zone around the French border was a dangerous area to be in carrying money or valuables because you could be stopped and interrogated by the CRS (as I once was, driving a brand-new van owned by my then-employers, an Embassy, with cases of wine in the back, being shipped from the embassy to one in another country. It gave me some satisfaction to be able to tell show them my "ordres de mission" and tell them they had no right to search the van without authorisation from the Foreign Ministry. But I thought all along of the mysterious account, which I read in an old issue of the Sunday Times Magazine, of a load of World War II gold that had been seized that way en route to Switzerland, and which had disappeared from the radar, presumably corruptly. The point of the story was that the only way the car could have been targeted is if somebody in the Swiss bank had tipped off the CRS, presumably in exchange for a reward. Well, we know now that happens, think: Liechtenstein Massive Tax Evasion Scandal in Germany: The Liechtenstein Connection - SPIEGEL ONLINE - News - International

Sorry to get further off topic, but it's not really off topic at all, is it? 

I'm back in London next week with a stack of tax returns to finish and a "décalage" problem relating to the British ecclesiastical/tax year conflicting with the US tax year. The sources of grief and potential double taxation are endless.


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## liquiduty (Oct 23, 2010)

This is probably far too late for the original poster but I have used www highfieldexpat co uk and have been pleased with their services and pricing.


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## ktz (Jul 20, 2010)

Sorry to resurrect this thread, but in the 3 years I have lived in Britain, every year around this time of year (e.g., LATE, tax-wise), I end up back here rereading the information in this thread (half-frightened, half-enlightened).

The one thing that always happens (apart from being frustrated I cant directly message Punklitch2 and Bev to attempt to hire them on a freelance basis!) is that I still leave the thread without many avenues to take in my hunt for a reasonably priced, honest tax accountant that can handle both US and UK returns.

I have contacted many in my hunt for these enigmas (included the registered IRS agents in the UK), but everything has been well out of my budget. I think that I likely fall into the trivial category mentioned by Punklitch2 and paying £1200 to have someone help with my returns seems a bit strange as it shouldn't be taking more than 20 minutes for most of these folks (more for me obviously). that's not to devalue their knowledge at all, but the cost should be somewhat proportionate to the time in my opinion.

That being said, does anyone have any new insight they would like to share in regards to recommended accountants capable of straddling the line between US and UK tax rules and filings? It would be great to get a snapshot as to how others are handling it.

@Punklitch2 and Bev—I really appreciate all the insight in this post. If either of you fancy adding a client to your roster, please get in touch!


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## thebcs (Dec 31, 2011)

I'm interested in the Enrolled Agents, but can't find out much on Bev's link. I'm specifically looking for help with UK taxes. I need someone familiar with both UK and US, and how they work together, and, of course, for the lowest price. But honesty and competence are more important than the price.


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## Bevdeforges (Nov 16, 2007)

thebcs said:


> I'm interested in the Enrolled Agents, but can't find out much on Bev's link. I'm specifically looking for help with UK taxes. I need someone familiar with both UK and US, and how they work together, and, of course, for the lowest price. But honesty and competence are more important than the price.


I've been living in Europe for 20 years now, and frankly, even among the high priced tax attorneys, I haven't found anyone who is really into the art of juggling both sides of the tax situation for us US expats. Enrolled agents are qualified to do US taxes. Some are also UK (or other country) tax preparers, but it varies from individual to individual.

The US is rather unique in requiring their nationals overseas to file US taxes, so you best bet might be to find a US citizen accountant or enrolled agent practicing in your country (i.e. in the UK). Not always easy to find, I realize. Or combine a good UK tax accountant with doing your own US taxes with one of the software programs available (TurboTax, TaxCut, or whatever else is available online these days).
Cheers,
Bev


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## blimey (Nov 8, 2013)

I'm a Brit repatriating back to the UK after 30 years in USA. I've been quoted a rather large fee by the aforementioned Buzzacott folk to do my US and UK taxes...
I've read and re-read this thread with interest, but can't quite determine what path to choose. 
There's a company who have a flat fee, not sure if we can name names or not! Their methodology and background looks interesting, but I'm nervous about this first dual filing. I'm resident in USA until July this year, still being paid in USA until my company switches my salary to the UK office. 
Any advice would be most gladly received. I've probably missed something important somewhere!
Thanks
Rich
(Apologies for resurrecting the thread once more, I'm surprised there aren't more chats about this topic!)


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