The US Tax Cuts and Jobs Act 2017 has introduced new legislation aimed at taxing US multinational corporations which are headquartered overseas.

The Act has also imposed a one-off tax on the retained earnings of foreign companies controlled by US persons who are non-US resident.

This is generally being referred to as the ‘Section 965 repatriation tax’ with rates as high as 17.5%. 

There is scope to amortise the tax due under this provision over an eight year period, but in order to do so the taxpayer must pay the first instalment in full (or, if estimated, to at least the full value of the first instalment once it is ascertained) by 17^th April 2018. Otherwise the right to pay in instalments is lost.

Now is the time for US persons resident in the UK with UK company ownership interests to act before the IRS approaches them directly and to amortise the payment where possible.

Contact me via david.rickwood@shawgibbs.com or +44(0)1865 292 200 to arrange a consultation, via phone or in person.