Cablegate: Non-Dom Tax Issue: Washington Guidance

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RR RUEHAG RUEHBL RUEHDF RUEHED RUEHIK RUEHLZ RUEHROV
DE RUEHC #0660 0592359
ZNR UUUUU ZZH
R 282356Z FEB 08
FM SECSTATE WASHDC
TO RUEHLO/AMEMBASSY LONDON 5289
INFO EU MEMBER STATES COLLECTIVE
RUEHBL/AMCONSUL BELFAST 0694
RUEHED/AMCONSUL EDINBURGH 0873
RUCPDOC/DEPT OF COMMERCE WASHINGTON DC
RUEATRS/TREASURY DEPT WASHINGTON DC 9276

UNCLAS STATE 020660

SIPDIS

SENSITIVE
SIPDIS

E.O. 12958: N/A
TAGS: ECON EFIN ETRD CASC EINV UK
SUBJECT: NON-DOM TAX ISSUE: WASHINGTON GUIDANCE

REF: LONDON 475

1. Per refel, post requested guidance on proposed talking
points to respond to questions from H.M.Treasury (HMT)
regarding the proposed taxation of non-domiciled foreigners
in the UK, including Americans. As post noted, Amcits are
chiefly concerned about possible double taxation and timing.
Post may use the following, cleared points as guidance.

2. Begin points:

-- The U.S. government respects the right of the United
Kingdom to tax its citizens and residents in any manner it
sees fit. Many long-term, resident American citizens,
however, have expressed concern to our Embassy in London
about the proposed timeline for implementation of changes to
the tax code for non-domiciled residents.

-- The U.S. government supports the requests by its
citizens that they be given a reasonable amount of time
between the publication of the final legislation and the
implementation of the law in order to arrange their financial
affairs to suit the new tax rules.

-- A reasonable waiting period between the publication of
the final legisltation and its implementation would also give
the U.S. Treasury time to analyze the changes fully and
determine the creditability against U.S. taxes of any new UK
tax charges.

-- U.S. tax officials are prepared to discuss with you the
U.S. tax issues raised by the proposed charge and answer
questions you may have.

End points.

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