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Jan 29, 2016 at 11:07 comment added davmp The question is about US citizens (tax residents) living in the UK.
Jan 29, 2016 at 10:38 comment added Will Tax treaties normally prevent double taxation on income and allow you to use tax-credits to offset taxation in the receiving country. In this case there wouldn't be anything to offset besides the 10% dividend tax. There doesn't seem to be any definite information. The closest you will get is speaking to a qualified tax advisor in the United States. If you don't intent to leave the UK, and are not a US citizen/tax resident I'm not sure why you would be interested in this question.
Jan 29, 2016 at 10:35 comment added davmp Uh, don't tax treaties specify both what is taxed and what isn't? Not to say every situation has to be covered, but I'd think situations where the local country doesn't tax would be explicitly covered in such a document if the other country will tax. Oh, and this is research to determine whether to open and participate in an ISA. No part of the question was concerned about leaving the UK.
Jan 29, 2016 at 10:09 comment added Will Double taxation treaties aren't relevant to ISAs because you don't pay tax on them in the UK. From the information I can find it is treated differently dependent on the investments, but you will definitely be paying income tax on dividends and CGT on gains. This is definitely a question for a qualified tax specialist. Your ISA may also be closed if you move to the US because of FATCA obligations. Your best bet is most likely withdrawing from the ISA and transferring your account to the states, so it's easier for tax purposes.
Jan 29, 2016 at 9:58 comment added davmp I'm not trying for tax avoidance here, I'm trying to understand US taxation of ISAs. Your source says right at the beginning "... this post is just me looking at the question and coming to a conclusion. The IRS may well come to a contrary conclusion." So doesn't seem too definitive to me. Instead, i'm looking for equivalent guidance in the taxation treaty as this for pension schemes: hmrc.gov.uk/manuals/dtmanual/dt19939h.htm. Do you have an equivalent source for treating it like a non-tax-advantaged investment account?
Jan 29, 2016 at 9:46 history answered Will CC BY-SA 3.0