The US Internal Revenue Service (IRS) has confirmed that the UK's remittance basis charge (RBC) is a creditable tax for US tax purposes. UK-resident US taxpayers will therefore be able to treat it as a foreign tax credit in their US income tax calculation.
For full details, see IRS Revenue Ruling 2011-19.
This ends the uncertainty that had existed on this point since the introduction of the RBC, and enhances the UK's position as an attractive location for mobile US taxpayers.
Please contact Ashley Hill for further information or advice in connection with the RBC.