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    gholey's Avatar
    gholey Posts: 1, Reputation: 1
    New Member
    		  
    #1

    Jul 6, 2015, 01:27 PM
    UK citizen on L1-A visa NY taxpayer winding up UK company tax implications in the US?
    Hi, I am a United Kingdom citizen as of April this year 2015 working legally in the US sponsored on a L1-A visa and working in New York. I am in the process of winding up a UK limited company I had operated as a independent contractor 2009-13.

    I would like to know if I will have a US tax liability on the dividend/cash I will receive upon liquidation, or if my liability will be to te UK.

    Many thanks, Graham
    AtlantaTaxExpert's Avatar
    AtlantaTaxExpert Posts: 21,836, Reputation: 846
    Senior Tax Expert
    		  
    #2

    Jul 7, 2015, 10:31 AM
    Assuming you stay in the U.S. for at least 183 days in 2015, you will become a dual-status alien on the date you hit 183 days in country.

    At that point in time, you are liable for taxation on ALL world-wide income earned starting on the date you first arrived in the U.S. in April, 2015.

    That being the case, any dividends or cash received from your U.K. limited liability company IS subject to U.S. taxation. You will be able to offset the taxes due by filing Form 1116 to claim the Foreign Tax Credit for taxes paid by you to the U.K.
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