Bogleheads.org

Would the calculation of capital gain on each be calculated off the base price it was bought at in 2019 (even though I was not living in UK at the time)? If so that would be a gain of 10k on stock A and a loss of 5k on stock B for a net gain of 5k. This one, sort of. The UK does not provide any step up/down in basis on becoming resident. And potentially worse (or better), you need to use the UK/currency exchange rate in effect on date of purchase to find your basis in GBP, and (assuming non-GBP stocks) the exchange rate in effect on date of sale to find your sale proceeds in GBP. Your capital gain for UK tax purposes is the difference in these two GBP values. Also if gains/losses are calculated based off the price in 2019, would it make se...

Hyperborea wrote: ↑Wed Mar 22, 2023 3:09 am

TedSwippet wrote: ↑Tue Mar 21, 2023 4:03 am and this provides an arguable case that a treaty such as this protects against not just US tax but also the 10% US early withdrawal penalty.

This seems correct from the standpoint of the US tax treaties but do you know of any institution that will not take the 10% early withdrawal penalty? Any case law? Private letter rulings?

No (to all three of your questions!). Basis is nothing more than the opinions of a few firms that have been posted in the past.

Welcome. What address should I mention on the W-8BEN form, and how will that protect me from capital gains tax and or dividends taxation? From the W-8BEN instructions : Line 3. Your permanent residence address is the address in the country where you claim to be a resident for purposes of that country’s income tax. If you are completing Form W-8BEN to claim a reduced rate of withholding under an income tax treaty, you must determine your residency in the manner required by the treaty. Do not show the address of a financial institution, a post office box, or an address used solely for mailing purposes. If you do not have a tax residence in any country, your permanent residence is where you normally reside. So assuming you are not a tax-reside...

You are correct about me being wrong about the tax rate. On the treaty, its difficult to interpret and I haven't seen anything concrete online on the treatment of 401k for people moving to India, and it might be safer to assume it doesn't exist. Except that it does exist. While you can pretend that it does not, the assorted tax authorities (IRS, Indian) will nevertheless expect you to use it. For example, Article 20 paragraph 1 restricts tax on US pensions withdrawals by US nonresident aliens living in India to only India. If you 'voluntarily', or accidentally, nevertheless pay US tax on these withdrawals, India is under no obligation to let you off or allow you a tax credit for the US tax you paid. The treaty says India has to allow you a...

I've been using Vanguard as a non-US resident for many years. I filed a W-8BEN which has a foreign residence address ... Similar, UK based US nonresident alien with W-8BENs at Vanguard. However, I have run into several restrictions with my Vanguard account, many/most of which are difficult to connect logically to not being a US resident. No voice identification; no checkwriting; no access to the Vanguard app; and restricted to mutual funds only, with no brokerage option or way to hold Vanguard ETFs. (The latter is particularly weird, since the UK has unfavourable tax rules that capture Vanguard mutual funds but not most Vanguard ETFs.) As for 'policy' ... it's unclear if Vanguard, or for that matter any provider, has one. Results reported ...

mconejoh wrote: ↑Mon Mar 20, 2023 7:18 pm Also, is the higher expense ratio of the VWRA of 0.22% worth it compared to the VTI of 0.03%?

You are comparing two different things. VWRA is an all-world ETF; VTI is US stocks only. A better comparison is VWRA against VT.

mconejoh wrote: ↑Mon Mar 20, 2023 7:18 pm So does the tax advantage of using a non-US ETF worth it to compensate for the extra cost?

For you, yes. There are some worked examples and an online calculator in the wiki:

Nonresident alien investors and Ireland domiciled ETFs - Bogleheads

My effective tax rate is likely 18%+ for just Federal taxes and bound to increase with time. To me option 2 make sense if I could time the withdrawal after leaving the US in the first few years if I am in a low tax bracket (or tax rate + 10% penalty < 18%). Are you sure you are making the right comparison here? Money paid into a 401k is pre-tax and so effectively saves tax at your marginal tax rate , not your effective tax rate. Beyond this, check how 401k withdrawals are treated by your local country tax (India?). The treaty, if any ( this one ?), may give some clues. In particular, some treaties reserve tax rights on pension to residence country only, and this provides an arguable case that a treaty such as this protects against not just...

In other words, will the IRS honor the fact that I paid tax to the UK on this unreported income, or will they say that they don't recognize that type of tax so my cost basis stays where it was? Not a US citizen or other US 'taxable person', so no direct experience, but I strongly suspect the answer will be the latter, meaning you have to maintain two basis numbers for your holding -- one for the UK, the other for the US. The problem here is a mismatch of income types. The UK taxes "unreported" fund income as if annual dividend; the US will roll it all up as if capital gain on sale. And the offset here, both in income type and in time (there could be years or decades between unreported income and fund sale) creates a strong probab...

rettir wrote: ↑Wed Mar 15, 2023 11:03 am Vanguard offers "tax-free" conversions from certain mutual funds to their ETF counterparts. I suppose this means that the IRS accepts this as a tax-free procedure. Does HMRC view these conversions as tax-free as well?

Almost certainly not. The Vanguard fund/ETF equivalent pairs have different CUSIPs, and this makes them different and distinct for UK tax.

jjmaddison wrote: ↑Wed Mar 15, 2023 4:03 am What's with the money on IBIE brokerage account?

Hard to say. It may depend on where and how IBIE places customer cash deposits, and only they can tell you that.

Worst case, Ireland has a €16,750 exemption. That's pretty low -- it makes the US's own stingy $60,000 look generous by comparison -- but perhaps adequate given that a brokerage cash account is not the place to keep any long-term cash. As with a US brokerage, just don't die while rebalancing and you'd be fine.

jjmaddison wrote: ↑Wed Mar 15, 2023 2:56 am Also, why it doesn't apply to ETFs in IBIE?

Nonresident alien investors and Ireland domiciled ETFs - Bogleheads

From Revenue Ireland:

23.6 Exemption of certain investment entities CATCA 2003 s.75 provides an exemption from tax for gifts and inheritances of units of certain investment entities (defined in the TCA 1997, Part 27). Units held in collective investment schemes, common contractual funds, investment limited partnerships or investment undertakings are exempt from tax in cases where neither the disponer nor the donee or successor is domiciled or ordinarily resident in the State, at the date of the disposition and at the date of the gift or inheritance, respectively.

I switched all my US investments with Vanguard to UK reporting ETFs before I left the US. I then moved them to a US IBRK account. ... I'm presuming I need to send Vanguard the tax treaty form so they don't tax me at 30% ... Unless you hold any of these investments directly with Vanguard, or have left a 401k, IRA, or other stuff with Vanguard, there's no need to send Vanguard a W-8BEN. If your only Vanguard holding is VOO and VTI at IBKR, it is IBKR who need (and likely already have) a W-8BEN, since they are the party who will be dinging you for 15% US/UK treaty rate tax on dividends paid by these ETFs. Any reason to keep VTI and VOO. Notwithstanding a desire to move to a more globally balanced portfolio, there are some modest but useful ta...

Welcome. My country does not have a tax treaty with Ireland. What will this mean for taxes? Will I have to file and pay taxes in Ireland? No Irish tax entanglements. Ireland does not tax dividends or gains paid by Ireland domiciled ETFs to non-Irish residents, and does not apply its inheritance or estate taxes to non-Irish residents who hold these ETFs. There's also a point people make, that by investing in the Ireland domiciled ETFs , you get to take advantage of tax benefits and not pay full US taxes. There are assumptions being made there that I'm not clear on. Why are US taxes even relevant, if I'm investing in a fund in Ireland? US taxes are relevant if the ETF holds US stocks. If you hold your US stocks through a US domiciled ETF (and...

India has a poor US tax treaty, with a 25% rate on dividends paid to Indian residents who are not US citizens. Compare to the 0-15% dividend rate you can achieve if you use Ireland domiciled funds rather than US domiciled ones. For the last part, is it applicable on my 401k too? It is with Fidelity (FID FREEDOM 2040 K6 (FHTKX)). From the US perspective, no. You do not pay any US dividend or other withholding tax on the internal gains or dividends that arise inside a 401k or IRA, either as a US resident or citizen or as a nonresident alien. I do not know how India will view your 401k account when you move back there, though. Some countries recognise US 401k and IRA accounts as pensions, but some do not. Article 20 paragraph 1 of the US/Indi...

I have around $125k in 401k, which I will keep as it is. Not touching till my retirement in 15 years. ... (4) IF I should leave this money in US and eventually move periodically to India, what are my options to invest here in US? What follows assumes that you are not a US citizen, and if a green card holder, you will surrender the green card on leaving the US. If this is not the case, please post a follow up. India has a poor US tax treaty, with a 25% rate on dividends paid to Indian residents who are not US citizens. Compare to the 0-15% dividend rate you can achieve if you use Ireland domiciled funds rather than US domiciled ones. Additionally, India has no US estate tax treaty. This means that anything above $60,000 you hold in the US a...

I'm trying to see if this tax will imply some sort of "constant watch" on the account to make sure something doesn't get to 60k, which is fine, but I want to know what is that something . The something is 'US situs' assets. Predictably, the US's definition of 'US situs' is unintuitive and illogical. For non-US investors such as yourself though, it would typically include US stocks, US domiciled funds and ETFs, and a cash holding at a US broker, but exclude non-US stocks and non-US domiciled funds. So in practice, if you hold only Ireland domiciled ETFs as planned, all you need to do is to make sure your cash balance at IBKR never exceeds $60,000. Full details in the wiki (be sure to look at its footnotes and references): Nonresid...

Anon9001 wrote: ↑Tue Mar 07, 2023 1:04 pm Just to further bolster the point the Global Index is a closet US Index a Scatter Plot of the Monthly Returns of MSCI World USD and MSCI USA USD show that they have a pretty strong correlation ...

Nothing new here. Given that the USA is a large component of the MSCI World index -- and often its largest component -- maths alone make it virtually certain that these two will show a close correlation.

But enough of my soapbox, I know we both think the US system is outrageous. We do. The difference between us is that I'm free of it. :-) If you haven't already seen it, this Tax Notes International article on FATCA, published in January, offers a quite entertaining and refreshingly direct take on the whole nonsense. Selected quotes: Dear IGA Partner: Please urge your resident individuals to perform the requested tax compliance actions, even though it does not benefit your country one bit, and only benefits the U.S. fisc. Do this for Uncle Sam because we’re telling you to. - Yours truly, the IRS. Dear IGA Partner: We would do this menial task ourselves, but it seems that we can’t because the individuals in question are not U.S. residents an...

Nibbling around the edges even if they did do it. While I welcome anything that avoids pointlessly wasting my time filling in forms, double reporting on FBAR and 8938 is very low on the list of pain points for US citizens abroad - just one of the most obviously silly. It is less about the waste of time though, than it is about the outrageous penalties the IRS applies if you don't waste this time, compounded by their hiding the requirement to waste it so well that you may never find it. Not everybody has the IRS home page as their browser's new tab setting. The second part of this recommendation, not requiring either of these forms for home country accounts, would at least be a huge weight off for many. As for FATCA itself, TIGTA reports th...

The "good" news is that if you've done an FBAR, you've got almost all the information you need for the 8938 - just wasting time transcribing information the US government already has into a different form. ... From the National Taxpayer Advocate 2022 PURPLE BOOK : Legislative Recommendation #8 Harmonize Reporting Requirements for Taxpayers Subject to Both the Report of Foreign Bank and Financial Accounts and the Foreign Account Tax Compliance Act by Eliminating Duplication and Excluding Accounts Maintained by U.S. Persons in the Countries Where They Are Bona Fide Residents Best not to get too excited at the prospect. The Taxpayer Advocate Service suggests this regularly; in fact, almost every year since FATCA passed in 2010. The ...

However, I have not been able to get any conclusion from IBKR and out of an abundance of caution I include the account on my disclosures. I think that's probably the right answer to every " should I report this? " question regarding IRS form 8938, FinCEN form 114, and the plethora of other "informational" reporting forms that the IRS spews out. These forms serve no purpose except to generate or increase potential penalties. There are penalties for under -reporting but none for over -reporting. Waste no time trying to decipher contorted IRS verbiage. Simply (over-)report wherever the IRS has, as usual, provided zero clarity. I am a US citizen living in Europe. I have an Interactive Brokers account through Interactive Bro...

asteroidnix wrote: ↑Fri Mar 03, 2023 2:05 pm Downside of HMRC Reporting Irish domiciled funds is that they will create an ERI reporting burden.

Not an issue in an ISA.

I am seeking advice/opinions on the UK Estate Tax for non UK residents , and if there is a way to reduce these taxes. On my reading of the facts given, you should have no risk of exposure to UK inheritance tax if you use a UK based brokerage and hold Ireland (or Luxembourg) domiciled funds or ETFs. From HMRC: How Inheritance Tax works: thresholds, rules and allowances: When someone living outside the UK dies - GOV.UK If your permanent home (‘domicile’) is abroad, Inheritance Tax is only paid on your UK assets, for example property or bank accounts you have in the UK. It’s not paid on ‘excluded assets’ like: foreign currency accounts with a bank or the Post Office overseas pensions holdings in authorised unit trusts and open-ended investmen...

Assuming that I'll pay income on any gains that are actually distributed either way, would it make sense to hold a non-reporting fund now, then only sell it in a few decades once I’m back in the US? If you can dig out the numbers you can probably take a stab at estimating any advantage. My guess is that unreported income for most funds will be negligible in the grand scheme of things (although, if a fund isn't UK reporting then you may not have any easy way to determine how much unreported income it generated, because it doesn't have to produce that number) Taking VTI as a (hopefully) typical fund example, if you look through the Vanguard report that baron_greenback linked upthread, you'll see that its unreported income is tiny or zero for...

I’m 50/50 at this point whether I’ll end up retiring in the UK or the US, so I’m wondering whether it’s better for me to hold non-reporting funds, and to just not sell them until I move back to the US. As far as I understand it that would be fine with HMRC, is that other people’s understanding? Yes. But. I think you'll struggle to find a UK non-reporting fund that meets PFIC regulations but never pays out any dividends or capital gains distributions. I think that's what you'd need in order to entirely avoid any UK tax until either you sell or you leave the UK. The problem here though is that you (US citizen) can realistically only use US domiciled funds or ETFs, and US domiciled things must, under US regulations, pay out dividends and perh...

tubaleiter wrote: ↑Wed Mar 01, 2023 7:58 am So it feels like the IRS kind of wants to exclude UK pensions, but based on what they've actually written, they haven't.

Perhaps. However, I'm not as charitable as you.

My sense is that the IRS made minimal (likely zero) effort to understand how any other country's pension schemes worked, but simply went ahead and published guidelines using guesswork and gut feeling, based on the myopic and parochial assumption that every other country's pension rules operate broadly like the US's.

Rev. Proc. 2020-17 achieves little beyond the opportunity for the IRS to pat themselves on the back for having done something.

i am curious to see which part fail. I was thinking of this passage: .... The 10K contribution is quite low. I am wondering if this can be setup so that you have multiple SIPP or if all SIPP are considered one like in the US all class of the same IRA are the same IRA collectively. Adding to tubaleiter 's reply above ... the part of Rev. Proc. 2020-17 you quoted, with the $10k and $200k numbers in it, is actually from the ".04 Tax-Favored Foreign Non-Retirement Savings Trust" section. That might have covered ISAs, except that they are not "... exclusively or almost exclusively to provide, or to earn income for the provision of, medical, disability, or educational benefits", have a £20k/year (> $10k/year) contribution lim...

No. The UK taxes capital gains on non-reporting funds at higher income tax rates. Right good point, but the other points still stand I think - I don't get to keep that money now and let it grow, and I'm taxed now instead of during retirement. It's true that fully tax-deferred roll-up may eventually overcome a much higher final tax rate, compared to paying partial tax annually and then a low final tax rate. The problem is with the word "eventually". If you run some projections you could well find that break-even comes either too late in life to be useful, or (worse!) after death. When I did something similar for my own pension, which could grow over the lifetime allowance, it would take me more than 40 years of deferring a final 5...

rettir wrote: ↑Tue Feb 28, 2023 2:40 pm If I hold a non-reporting fund, I get to keep the “excess reportable income” and let it grow, and when I’m taxed on it it’s at the relatively low capital gains rate, ...

No. The UK taxes capital gains on non-reporting funds at higher income tax rates.

Does paying tax on this undistributed income mean that we end up being taxed twice? ... ... If the money is reinvested then you would pay tax on it again if it gives rise to income or capital gain. But the same would be true if it was paid out to you, and you reinvested it? If you reinvested manually then you would add the reinvested amount to your costs for capital gains tax, so that you only pay tax on the income (unreported, or otherwise) once. You do exactly this for 'excess reportable income' too: Do you owe tax on excess reportable income? - Monevator You can at least deduct the value of excess reportable income from any declarable capital gains you make in any particular year from selling some or all your fund. (Otherwise you’ll suf...

On my platform it's cheaper to hold ETF's and I would like to split them between two ETF providers for peace of mind - do the below two look like ok choices? These look fine to me. Because the indexes differ slightly, over time one 'all-world' index will probably slightly out-perform the other, but there's no way of telling which until after the fact. Also do any UK investors have any concerns with investing in ETF's with them being Irish domiciled rather than UK domiciled like OEIC funds usually are? Brexit (sigh!) casts a long shadow, but realistically it's hard to imagine that creating problems. Ireland domiciled funds and ETFs are such a common part of the UK investing firmament now that any substantive change to the rules on these wou...

One of the things which fascinates me is the extent to which posters always use the ticker codes for funds/ ETFs (and for that matter never post a link to a factsheet or web page for that fund). As it happens, you can find detail on all of the ETFs mentioned in the original post in our wiki: https://www.bogleheads.org/wiki/List_of_non-US_domiciled_ETFs#IWDA https://www.bogleheads.org/wiki/List_of_non-US_domiciled_ETFs#EMIM https://www.bogleheads.org/wiki/List_of_non-US_domiciled_ETFs#IUSN https://www.bogleheads.org/wiki/List_of_non-US_domiciled_ETFs#EUNA Who are these people who carry these around in their head? It's a bit like reading a foreign language where you don't have much vocabulary - the nouns are just big blanks. It's the topic a...

MH2 wrote: ↑Sun Feb 19, 2023 2:10 am Other options:

1. EU citizen wife
2. Move to a country with a different interpretation on 1286/2014

3. Renounce US citizenship, and live free.

The United States and Chile reached an agreement in 2010 to set the interest rate of the dividends to 15%, but the plenary of the Senate of the USA, still don't approve that agreement. I suppose that they will approve that in this year, ... I would bet real money that the US will not ratify this treaty this year, and might even risk a small sum on it never being ratified. After all, we've seen close to thirteen years of US heel-dragging so far. And in the event that I am wrong and the US does finally get round to doing what it should have done over a decade ago, that still leaves you with a potentially large US estate tax risk . The current (but currently unusable) US/Chile tax treaty only covers income, not US estate taxes. This would be ...

Welcome.

Afloat6099 wrote: ↑Tue Feb 14, 2023 3:50 pm I have all planned to start investing in my portfolio (Only VT) tomorrow, ...

What is your home country? If you are not a US citizen, then unless your country has good tax treaties with the US it will often be better for you to avoid US domiciled ETFs such as VT, and instead use Ireland domiciled equivalents, for example VWRL.

Full details in the wiki: Outline of non-US domiciles - Tax issues

Welcome. i found this on the wiki: “Irish investment funds are not subject to any taxes on their income (profits) or gains arising on their underlying investments. In addition, there are no Irish withholding taxes in respect of a distribution of payments by investment funds to investors or in relation to any encashment, redemption, cancellation or transfer of units in respect of investors who are neither Irish resident nor ordinarily resident in Ireland, provided the fund has satisfied and availed of certain equivalent measures or the investors have provided the fund with the appropriate relevant declaration of non-Irish residence.” https://www.bogleheads.org/wiki/Nonresident_alien_investors_and_Ireland_domiciled_ETFs Does this mean that th...

What is the situation in Europe? Are European mutual funds priced at the end of the day, as in the US? If not, are limit orders possible? No direct experience of NL, but in general it seems that priced once a day but usually not at the end of the day seems normal. Different funds may have different price points, which creates a "cut off" time after which your trade won't occur until the next working day. A typical cut off time is around 11am or midday. Fidelity's description of the UK situation (no idea if this extrapolates to NL, but it seems at least likely): Understanding Forward Pricing for funds (not shares) Regarding ETFs, our contact at the bank wrote that ETFs are traded via "market" orders. Did she mean that on...

So since Denmark has higher taxes, it doesn't seem to me there is any cost on becoming US citizen. Just the burden of doing some taxes. Too reductive. It's a recurrent theme in the US that European and many other non-US tax rates are higher than US ones. And it may be true for headline, marginal, and maybe average rates, perhaps provided you exclude high-tax states like NY and CA, but within this sweeping generalisation there are a lot of cases where living in one of these "higher tax" countries gives a US citizen no protection whatsoever from having to pay US tax and ending up with a higher overall tax bill than their non-US citizen peers. The clearest example of this is accounts that are locally tax-advantaged or tax-free, but ...

international001 wrote: ↑Thu Feb 09, 2023 7:33 pm I wonder what means when the use of may is used in a treaty. ...

Already answered for you, in this thread: viewtopic.php?p=6307387#p6307387

Welcome. I am an expat (non-American) living and working in China. I do my trades through a brokerage firm based in Hong Kong. I know that China has a tax treaty with the US so I should really only have to pay 10% WHT. However, my HK broker says I am subject to the 30%. Has anybody had experience with this or something like it? Love to hear your views. It sounds like your broker is confused. Hong Kong is not covered by the US/China tax treaty; perhaps that's their issue. As a practical matter, you should be able to recover two thirds of the 30% withheld to the US by your broker, taking you back to the correct 10%, by filing a 1040-NR tax return with the IRS (followed, typically, by a loooong wait). If you search the form's instructions you ...

That's a good point. I agree, but didn't think Ove would end up paying more in taxes by keeping the green card. I just didn't think interest would be that high. At 2.3% (Danish long rate), you'd have to have a considerable amount (>$500k) to exceed the $12,950 standard deduction (that an NRA doesn't get). Perhaps. Probably, even. But again, it depends. Remember that any US pension income itself counts towards using up the standard deduction (full US SS alone might consume all of that). You cannot use the FEIE to protect pension income. Also, any US savings, so not just Danish bank accounts or similar, but worldwide ones. Beyond this, several other tax-related dragons lurk. For example, making any local investment in funds or ETFs is likely...

So I thought if bank interest wasn't too high (since Danish income would get dragged into the US return) that it might work out favorably especially with the standard deduction that non-resident aliens don't get. Right. As mentioned before, it's a cost-benefit decision. At one extreme, the treaty arranges things so that a Danish resident US citizen living purely on US SS payments apparently faces a much lower total tax rate than an NRA in similar circumstances. (Assuming the NRA cannot reliably apply the treaty 'Non-discrimination' clause, Article 24.) At the other extreme, because of the US's precious citizenship based taxation, a Danish resident US citizen living purely on Danish or other non-US income could well find a US tax liability ...

typical.investor wrote: ↑Thu Feb 09, 2023 1:19 am Again, my comments were not meant to suggest re-entry on an old green card or after a year outside is easy. Only that legally the status of resident is not revoked until voluntarily abandoned or adjudicated as such. And it's clear the IRS keeps you on the clock until then.

Stated more simply, "US permanent resident" is a sliding scale. It is much more permanent for tax purposes than it is for immigration purposes. :-(

So, in the particular case of poor Uncle Ove, if he files the I-407 and ditches the green card, but has a US 401k or IRA, it does look like there may well be a lifelong requirement to file a wretched 1040-NR and get any overwithholding back from the IRS (with of course a long delay; let's just say the IRS does not prioritise 1040-NR returns). That sucks. Can you explain? Dont't 401k/IRA qualify as pension and therefore US will withold 30% for a NRA They do, and it will. But in this case, US withholding will not match US tax liability. The treaty says which country may tax pension withdrawals (and this case it is exclusively the paying country, so US for a 401k/IRA), but nothing about how that country may tax them. If you're not entirely pr...

As a Singapore resident, I am wondering if I have to pay extra taxes on the dividends that I received from the US-domiciled ETFs (VTI specifically) in addition to a 30% withholding tax. Not a Singapore resident, but based on information in Investing from Singapore , it seems that these dividends don't face additional tax in Singapore. Have you already moved from the US to Singapore, or are you still in the US? If you now live in Singapore, is there a specific reason why you still own VTI, and have not switched to equivalent non-US domiciled ETFs? From your previous thread : I am a Taiwanese citizen who has been living in the US as a resident alien without a green card. I plan to relocate to Singapore for work and might not return to the US...

typical.investor wrote: ↑Tue Feb 07, 2023 1:51 pm You need to know that your currency exposure is not EUR or USD. It's the exposure of the companies in the funds -- where they earn their revenue and have their expenses.

... as explained -- and arguably, flogged to death! -- in Non-US investors and ETF currencies. Also, Currency risk for non-US investors on the futility of comparing percentage returns across different currencies.

If not surrendering the green card has possible benefits, they should be explored because under US law, he is a US person until he voluntarily abandons the status or it is adjudicated as taken away. Just one further thought on this. If, for whatever reason, not surrendering the green card so as to retain 'US taxable person' status is the choice, he might as well go the whole hog and take out US citizenship before leaving the US. The US tax pain gets no worse, but at least then he has the option to visit or even live in the US without having any threats of hassles like immigration judges and so on, and has a vote (for what that's worth). The only thing that worsens is that if he changes his mind later on, renouncing US citizenship costs $2,...

cjjccnj wrote: ↑Mon Feb 06, 2023 8:11 am If someone has earnt in $ for the last few years, in the US, from a US employer and wants to move back to UK, and transfer their $ to GBP. ... are any fx gains Taxable in the UK?

Was this "someone" UK resident and/or a UK taxpayer for the period over which these forex gains occurred?

My strong sense from your use of "earned ... in the US" is no, they were not. In which case, zero interaction with UK taxes for forex or, really, anything else not connected with the UK. If you're genuinely non-resident in the UK, and while you remain that way, anything that you earn, save, or invest outside the UK, and in any currency whatsoever, is not subject to any kind of UK tax (only the US and Eritrea tax their nonresidents).

Wow, I am surprised that withholdings would equal US liability. Since pension income is taxed by the US (source) at ordinary rates which vary, I didn't think a treaty would stipulate the US rate of tax and thus the withholding may be too much or too little depending on which bracket was ended up in. The extent to which this works depends a lot on the country, and the type of pension. It's not so much that treaties stipulate a rate for pensions; rather that they either reserve tax to either the other country (so withholding is 0%), or to the US (so withholding at some standard IRS-prescribed rate). In some cases then, 0% withholding and 0% US tax liability means it'd be pointless filing a 1040-NR for that. The only treaty I'm fully familiar...

Boogiebogle wrote: ↑Sun Feb 05, 2023 10:23 pm I would like to remain invested in US markets if I have a choice.

Which country will you be in once you leave the US? The US has a bunch of tax laws for nonresident aliens (which is what you'll be once you leave and don't have a green card) that effectively discourage leaving money in US accounts. Potentially high US dividend withholding tax, and the threat of confiscatory US estate tax on your account balances above just $60,000 (compare to $12M for a US citizen).

More in this wiki page: Nonresident alien taxation - Bogleheads