Section 104 holdings

Scenario Foreign shares (USA) and UK capital gains. I hold the same share in two different US brokerage accounts. When selling all the shares in one brokerage account but retaining the shares in the other brokerage account do the shares in each account constitute a single section 104 holding or two 104 holdings. i.e. Can each brokerage account be regarded as a separate 104 holding (much simpler). I'm not concerned about 30 day rules etc. none of the shares fall into that category. If only I could just sell specific lots, that fits in much better with the US system. If you regard UK section 104 as the UK equivalent of US average cost then having one brokerage account set to average cost and another set to First in First Out (FIFO) is totally possible in the US. You can also have each brokerage account set to average cost but the averages are separate for each account. That would be the equivalent of two section 104 holdings. I can see this getting extremely complicated if the capital gains system changes in the budget (index linking?) and I'm left with a partial 104 holding. Partial 104 holdings being a headache and the need to convert acquisition costs to pounds sterling further complicates the already complex calculations.

Hi,

You should keep your foreign shares and your UK shares separate if using S104 holding.  In a tax return you would show your UK share in the main SA100 and the foreign shares in SA106,

where you can claim a foreign tax credit for and overseas tax paid on them.  Have a look at:

Shares and Capital Gains Tax (Self Assessment helpsheet HS284)

Thank you.

Hi, These are two different US brokerages holding the same US share, not a UK brokerage and a US brokerage. SA100 doesn't come into it, it is all SA106. For the same US share held by two different US brokerages, is that regarded as one S104 holding or two S104 holdings? It would be much simpler without S104 holdings since US brokerages keep track of costs for each lot of shares independently but I guess I cannot do it that way. It has to be a S104 holding but is it one or two S104 holdings.