Accountant · Atlanta, GA · Member since 2015 · 1k+ posts · 1k+ votes
6y
Very unlikely that a tax professional will be an expert in both. Most US tax CPAs who deal with international tax law as it relates to the US will know US tax law very well and just enough about other countries' tax laws to be dangerous.
If you find someone who is an expert in both, be prepared for an (appropriately) high bill rate that will reflect the time and effort it's taken that person to get to that level. I'd expect four figures per hour...
Most taxpayers would have a US tax professional and a UK tax professional work together as advisors to get the holistic optimal strategy.
Accountant · Atlanta, GA · Member since 2015 · 1k+ posts · 1k+ votes
6y
Very unlikely that a tax professional will be an expert in both. Most US tax CPAs who deal with international tax law as it relates to the US will know US tax law very well and just enough about other countries' tax laws to be dangerous.
If you find someone who is an expert in both, be prepared for an (appropriately) high bill rate that will reflect the time and effort it's taken that person to get to that level. I'd expect four figures per hour...
Most taxpayers would have a US tax professional and a UK tax professional work together as advisors to get the holistic optimal strategy.
Investor · London · Member since 2017 · 160 posts · 82 votes
6y
Thanks Eamonn! I'm on my phone now and the name tagging doesn't seem to work. I'd pay that hourly rate these days because the impact of good advice is staggering given the complexity. As an example, I'm getting radically different answers on a key capital gains question from two different well qualified accountants and it could cost me $30k or so depending which interpretation is right. Good advice will also inform me if it's a total waste of time to do rental property in the USA or UK, to do flips , to do something completely different. If I could gain comfort that the advice was good I'd pay four figures an hour.
Very unlikely that a tax professional will be an expert in both. Most US tax CPAs who deal with international tax law as it relates to the US will know US tax law very well and just enough about other countries' tax laws to be dangerous.
If you find someone who is an expert in both, be prepared for an (appropriately) high bill rate that will reflect the time and effort it's taken that person to get to that level. I'd expect four figures per hour...
Most taxpayers would have a US tax professional and a UK tax professional work together as advisors to get the holistic optimal strategy.
Investor · London · Member since 2017 · 160 posts · 82 votes
6y
Granular examples, in 2020 high earners in the UK could face approx 70% tax on rental property income outside of an LLC. But if I do a UK LLC what are the USA tax implications. 1031 exchanges are good in USA but not recognised in UK. Once you are domiciled in UK which I am unavoidably for now, estate tax threshold is approx USD 500k Vs multi million in USA. How do real estate structures interact with these inheritance tax considerations.
Just like @Eamonn McElroy said - it's highly unlikely you will find one person who is an expert in both areas, and being half-expert is rather dangerous. In my firm, for example, we refer all International issues to another firm and share several clients with them.
You're more likely to find a bigger CPA firm with multiple CPAs, one of them being a RE expert and another a UK expert. Those firms are not cheap but may be the right choice in your situation.
Many thanks all for your great advice. I figured as much but never hurts to ask. Biggerpockets has drilled the value of persistence into me. Happy to keep talking on private message if any of your leads / referrals are interested. I know I have to go through AML checks, happy to do that.
Our company works with a number of foreign investors and they use 2 main CPAs that focus their practices on foreign real estate investors. I am not aware of their UK experience but they most likley be able to assist you. PM me and I will send you their information.
Investor · London · Member since 2017 · 160 posts · 82 votes
6y
@Charles Carillo, just wanted to thank you for the referral you sent me. I had been working on some other non real estate projects in recent months but I'm coming back to the real estate question. Today I just learned something big and new for me from your referral's video about the estate tax for non US citizens. Radically different treatment of estate tax for US vs non US citizens highlighting the importance of knowledge and mitigation. Anyways just a big thanks! I will reach out to your contact soon.