Sophisticated advice for your US / UK cross border matters

Effective planning depends on guidance from advisers who clearly understand how the two tax regimes interact with one another. 

Our US / UK private client team is highly experienced in advising internationally mobile individuals with US connections and has a well developed understanding of US tax considerations and their interaction with the UK tax system.

Estate planning and mitigation of UK inheritance tax and US transfer taxes 

• Estate planning, where there is both a US and UK connection, including the preparation of English wills, and mitigation of UK and US estate taxes.
• UK tax advice in respect of US entities, commonly used for US estate planning purposes, such as revocable trusts and LLCs.
• Mitigation of UK and US estate taxes under the US / UK estate tax treaty including in respect of US nationals returning to the US and certain investment products and trusts set up by US domiciliaries.
• Concluding on the UK tax treatment of trusts/grantors/settlors/ beneficiaries under the US / UK estate tax treaty. 
• UK tax and conveyancing advice in respect of acquisitions of UK residential property and tax-efficient holding structures.
• Advising US connected clients on the effective use of trusts and other entities for estate and tax planning. 

Powers of Attorney 

• Co-ordinating the preparation of powers of attorney in both the US and UK, including UK Lasting Powers of Attorney.

Relocations from the US to the UK and vice versa

• Pre-immigration and pre-emigration tax planning and UK residence rules.
• Advising US connected clients on their UK residence status and the new UK tax regime rules for “qualifying new residents”, “long-term residents” and transitional reliefs.
• Advice on UK visa options and nuptial agreements.

Estate administration

• Advising in respect of the administration of estates where there is a US connection, including obtaining a UK grant of probate where there is a US will. 
• Will and estate administration disputes, and financial provision claims involving US and UK estates.

Charitable giving

• Gifting to charities in a tax-efficient manner where there is scope for US / UK double taxation.

Family

• International marital and co-habitation agreements for spouses who have US connections.
• Advising in conjunction with US advisers on multi-jurisdictional financial issues on divorce or separation and resolving issues, such as relocation, in respect of children in the context of a divorce or separation.