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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: United States of America: Credit: Federal taxes

Federal taxes admissible for credit under both the old and new agreements

  1. Federal income tax.
  2. The Federal excise taxes [FET] imposed on insurance policies issued by foreign insurers is also available for credit, but;

under the old Agreement, in practice United Kingdom residents were exempted from it under other provisions of that agreement.

under the new Agreement, the exemption substantially remains - Article 7(5) - but is subject to the application of the “conduit arrangement” rules; see DT19884. Any case where relief is claimed for FET should be sent to CT & VAT, International CT before the claim is admitted.

Federal taxes inadmissible for credit under both the old and new agreements or unilaterally

Contributions under the Federal Insurance Contributions Act (sometimes described as ‘Social Security Taxes’).

Contributions under the Self-Employment Contributions Act (sometimes described as ‘Self-Employment Tax’).

Crude Oil Windfall Profits Tax (repealed with effect from 23 August 1988).

Environmental insurance resolution fee (EIRF).

Environmental insurance resolution assessment (EIRA).