US/UK Dual Qualified Charities

US citizens (and other individuals subject to US income tax) who are resident in the UK, may be subject to tax in either the US or the UK when they make contributions to charity unless the charity is dual qualified. The problem arises because the US income tax charitable deduction is only available for gifts to charities organised under the laws of the US, whilst UK tax relief is only available for contributions made to charities established in England and Wales and governed by English law.

This means that a donation made to a US charity supporting an English charity will not qualify for UK gift aid, nor will a US individual's contribution to an English charity supporting a US charity qualify for a US income tax charitable deduction (unless it is dual qualified).