Key contact
Peter Daniel
Partner - Head of Private Wealth
The Team
Our lawyers have the expertise and experience to provide you with creative, personalised solutions in a clear and understandable way.
Our Publications
Discover a wealth of invaluable guidance in the form of guides and brochures written by our expert lawyers.
Our UK/USA podcast series
Explore the nuances of some of the most common aspects of UK/USA cross-border tax and estate planning.
View profile
About
Professional advice on transatlantic tax and estate issues
Our Private Wealth team includes lawyers who specialise in providing guidance on a range of US/UK cross border matters. Co-ordinating with US advisers where necessary, we are able to provide a tailored and fully integrated estate plan.
Peter DanielPartner - Head of Private Wealth
+44 20 7468 7351+44 7879 842645peter.daniel@collyerbristow.com
Explore the nuances of some of the most common aspects of UK/USA cross-border tax and estate planning.
US/UK Tax Advice work highlights
Acting for UK residents inheriting wealth from the US via a US revocable living trust
We acted for UK residents inheriting wealth from the US via a US revocable living trust. Without careful attention, the clients would have faced UK tax at up to 45% on the inheritances and significant ongoing future US and UK tax and reporting requirements. However, with our analysis, we were able to recommend a way to receive the inheritances free from UK tax and entirely avoid those future administrative complexities.
Led by:
Advising a US resident couple on their cross border US/UK estate planning
We advised a US resident couple on their cross border US/UK estate planning. The clients had to take care because one of the spouses was not a US citizen, meaning that the marital deduction was not available for US estate tax purposes. However, the planning also needed to ensure that the UK inheritance tax spouse exemption was available on the first death. This involved a careful reworking of the clients’ existing US-focused estate planning. As sometimes occurs, making the planning slightly simpler also made it more tax-efficient overall
Led by:
Advising on pre-arrival tax and estate planning for UK relocation
We advised a client seeking to relocate to the UK on his pre-arrival tax and estate planning. With our assistance, and at very short notice, we advised on how he could generate significant quantities of tax-efficient ‘clean capital’ prior to becoming UK tax resident. This has allowed him to reduce his exposure to UK tax considerably on meeting his UK expenditure while he is here.
Led by:
Advising US citizens on their UK tax exposure as UK residents
We advised US citizens on their UK tax exposure as UK residents and why, perhaps initially counter-intuitively, the remittance basis of taxation would not be suitable in their circumstances. Following our advice, we managed to reduce the clients’ global tax exposure dramatically and pull them away from significant annual double tax exposure between the US and UK. This had been particularly problematic for the clients with regard to a US UTMA account they held.
Led by:
Spotlight
UK beneficiaries of US family trusts
The UK taxation of US trusts, and particularly living trusts, can be very different to the corresponding US rules. Before substantial wealth is settled on trust or distributed to a UK resident the terms of the trust must be considered carefully to ascertain if that UK tax can be mitigated.
We have advised UK beneficiaries of US family trusts, UK resident US grantors looking to settle new trusts and also the families of grantors who have died leaving their wealth through a revocable US trust.
Spotlight
UK Expats
UK individuals who have recently emigrated to the US need to be aware that they may remain within the UK tax rules for some time following their emigration. We recommend that UK advice be sought in such circumstances before any such planning is put in place.
We have acted for UK expats looking to establish new structures in the US (both those who have only recently left the UK and also those who have been US resident for some time but retain significant connections to the UK) and also those expats who are considering dismantling their US structures before an intended return to the UK.
Spotlight
US/UK marriages
“We have acted for numerous US/UK couples living both in the UK and US, including those with dual-citizen children and those looking to benefit wider family in each jurisdiction. Often the careful use of will trusts can ensure that there is no tax on either side of the Atlantic on the first death, and that tax is mitigated when assets pass to the next generation. We work with American advisers to prepare wills which achieve optimum efficiency in both the UK and US. Spouses need to make sure that they consider they know how and when US and UK tax will arise, and may wish to reflect on how to mitigate against unwanted taxation through tax-efficient Wills, lifetime giving and the appropriate ownership of the UK home.”
Services
We support our clients with individually tailored legal advice, in areas such as:
US/UK tax-efficient Wills
We can ensure that assets pass tax-efficiently between spouses and down to the next generation.
US living trusts
We can help you understand the likely UK tax consequences of UK residents receiving gifts and inheritances out of such structures and why revocable trusts are often inadvisable from a UK perspective.
Pre-arrival planning
We can explain the steps US taxpayers should take before coming to the UK, including how to ensure they can live tax-efficiently in the UK and avoid double taxation.
Trusts with US trustees and/or beneficiaries
We can help ensure that any UK tax arising to the trustees and beneficiaries does not clash with any corresponding US tax.
Lifetime estate planning
We can help you to structure any lifetime giving to ensure that gifts are tax-efficient in both the US and UK.
Ownership of the UK home
We can help US/UK spouses minimise any exposure to US tax on a future sale of the UK home.
Inheriting a US estate
We can help UK individuals who inherit US assets, including US land, US stocks and shares, Individual Retirement Accounts (IRAs), US life insurance proceeds policies and others.
US/UK philanthropy and charitable giving
We can help create structures to suit the philanthropic needs of charity trustees or donors, and advise on how to make cross-border donations in a tax-efficient manner.
US/UK Tax Advice Publications
CB Destination UK: essential pre-arrival planning
Collyer Bristow is highly experienced in acting for HNW/UHNW individuals looking to relocate or return to the UK. This document outlines the key tax, estate planning and immigration areas which may be relevant to you, your clients or your employees when moving to the UK.
Two countries separated by a common language:US/UK estate planning with trusts - US/UK estate planning with trusts
This document outlines how the UK may have a different tax treatment of US living trusts
and how the UK concept of domicile may give rise to UK tax in unexpected ways.
"[Collyer Bristow] advises on domestic and international wealth planning and is recognised for [its] extensive expertise in complex structuring with a significant multi-jurisdictional element"
Chambers & Partners, 2021
US/UK Tax Advice insights
Podcasts
Take it on trust (Part 2)Take it on trust (Part 2)
Listen now
Podcasts
Take it on trust (Part 1)Take it on trust (Part 1)
Listen now
Podcasts
The Average American – what should they know? (Part 2)The Average American – what should they know? (Part 2)
Listen now
Shorter Reads
Should I protect my finances ahead of US and UK elections?Should I protect my finances ahead of US and UK elections?
Read more
Podcasts
The Average American – what should they know? (Part 1)The Average American – what should they know? (Part 1)
Listen now
Podcasts
The Christmas Special!The Christmas Special!
Listen now
Podcasts
State of mind or question of fact? (Part 2)State of mind or question of fact? (Part 2)
Listen now
Podcasts
State of mind or question of fact? (Part 1)State of mind or question of fact? (Part 1)
Listen now
Podcasts
Planning Across the Pond (Part 2)Planning Across the Pond (Part 2)
Listen now
Podcasts
Planning Across the Pond (Part 1)Planning Across the Pond (Part 1)
Listen now
Podcasts
Jumping across the Atlantic?Jumping across the Atlantic?
Listen now
Podcasts
American Philanthropy (Part 2)American Philanthropy (Part 2)
Listen now
You might also like
Back
Need some more information? Make an enquiry below
US/UK Tax Advice key contacts
- peter.daniel@collyerbristow.comPeter
DanielPartner - Head of Private Wealth
Talk to Peter about UK trusts, tax & estate planning, International trusts, tax & estate planning, Private wealth, Probate and US/UK Tax & estate planning
US/UK Tax Advice
US/UK Tax Advice
UK tax and estate planning advice, with a US conscience.
For individuals with personal and financial connections in both the US and the UK, navigating the interaction between the two regimes on matters of tax, estate planning, trusts and succession can be complex. Individuals may have just avoided the pitfalls of one jurisdiction only to fall foul of the rules in the other. If you are in the position where you have interests across both sides of the pond, it is crucial that you work with advisors with experience in crafting suitable UK advice that is mindful of, and can coexist tax-efficiently with, concurrent US concerns.
Key contact
Peter Daniel
Partner - Head of Private Wealth
The Team
Our lawyers have the expertise and experience to provide you with creative, personalised solutions in a clear and understandable way.
Our Publications
Discover a wealth of invaluable guidance in the form of guides and brochures written by our expert lawyers.
Our UK/USA podcast series
Explore the nuances of some of the most common aspects of UK/USA cross-border tax and estate planning.
PROFESSIONAL ADVICE ON TRANSATLANTIC TAX AND ESTATE ISSUES
Our Private Wealth team includes lawyers who specialise in providing guidance on a range of US/UK cross border matters. Co-ordinating with US advisers where necessary, we are able to provide a tailored and fully integrated estate plan.
Peter DanielPartner - Head of Private Wealth
View Peter Daniel's profileAidan GrantSenior Associate
View Aidan Grant's profileDaniel SimonSenior Partner
View Daniel Simon's profileExplore the nuances of some of the most common aspects of UK/USA cross-border tax and estate planning.
US/UK Tax Advice work highlights
Acting for UK residents inheriting wealth from the US via a US revocable living trust
We acted for UK residents inheriting wealth from the US via a US revocable living trust. Without careful attention, the clients would have faced UK tax at up to 45% on the inheritances and significant ongoing future US and UK tax and reporting requirements. However, with our analysis, we were able to recommend a way to receive the inheritances free from UK tax and entirely avoid those future administrative complexities.
Led by:
Advising a US resident couple on their cross border US/UK estate planning
We advised a US resident couple on their cross border US/UK estate planning. The clients had to take care because one of the spouses was not a US citizen, meaning that the marital deduction was not available for US estate tax purposes. However, the planning also needed to ensure that the UK inheritance tax spouse exemption was available on the first death. This involved a careful reworking of the clients’ existing US-focused estate planning. As sometimes occurs, making the planning slightly simpler also made it more tax-efficient overall
Led by:
Advising on pre-arrival tax and estate planning for UK relocation
We advised a client seeking to relocate to the UK on his pre-arrival tax and estate planning. With our assistance, and at very short notice, we advised on how he could generate significant quantities of tax-efficient ‘clean capital’ prior to becoming UK tax resident. This has allowed him to reduce his exposure to UK tax considerably on meeting his UK expenditure while he is here.
Led by:
Advising US citizens on their UK tax exposure as UK residents
We advised US citizens on their UK tax exposure as UK residents and why, perhaps initially counter-intuitively, the remittance basis of taxation would not be suitable in their circumstances. Following our advice, we managed to reduce the clients’ global tax exposure dramatically and pull them away from significant annual double tax exposure between the US and UK. This had been particularly problematic for the clients with regard to a US UTMA account they held.
Led by:
SPOTLIGHT
UK beneficiaries of US family trustsopen
The UK taxation of US trusts, and particularly living trusts, can be very different to the corresponding US rules. Before substantial wealth is settled on trust or distributed to a UK resident the terms of the trust must be considered carefully to ascertain if that UK tax can be mitigated.
We have advised UK beneficiaries of US family trusts, UK resident US grantors looking to settle new trusts and also the families of grantors who have died leaving their wealth through a revocable US trust.
UK Expatsopen
UK individuals who have recently emigrated to the US need to be aware that they may remain within the UK tax rules for some time following their emigration. We recommend that UK advice be sought in such circumstances before any such planning is put in place.
We have acted for UK expats looking to establish new structures in the US (both those who have only recently left the UK and also those who have been US resident for some time but retain significant connections to the UK) and also those expats who are considering dismantling their US structures before an intended return to the UK.
US/UK marriagesopen
“We have acted for numerous US/UK couples living both in the UK and US, including those with dual-citizen children and those looking to benefit wider family in each jurisdiction. Often the careful use of will trusts can ensure that there is no tax on either side of the Atlantic on the first death, and that tax is mitigated when assets pass to the next generation. We work with American advisers to prepare wills which achieve optimum efficiency in both the UK and US. Spouses need to make sure that they consider they know how and when US and UK tax will arise, and may wish to reflect on how to mitigate against unwanted taxation through tax-efficient Wills, lifetime giving and the appropriate ownership of the UK home.”
US/UK tax-efficient Wills
We can ensure that assets pass tax-efficiently between spouses and down to the next generation.
US living trusts
We can help you understand the likely UK tax consequences of UK residents receiving gifts and inheritances out of such structures and why revocable trusts are often inadvisable from a UK perspective.
Pre-arrival planning
We can explain the steps US taxpayers should take before coming to the UK, including how to ensure they can live tax-efficiently in the UK and avoid double taxation.
Trusts with US trustees and/or beneficiaries
We can help ensure that any UK tax arising to the trustees and beneficiaries does not clash with any corresponding US tax.
Lifetime estate planning
We can help you to structure any lifetime giving to ensure that gifts are tax-efficient in both the US and UK.
Ownership of the UK home
We can help US/UK spouses minimise any exposure to US tax on a future sale of the UK home.
Inheriting a US estate
We can help UK individuals who inherit US assets, including US land, US stocks and shares, Individual Retirement Accounts (IRAs), US life insurance proceeds policies and others.
US/UK philanthropy and charitable giving
We can help create structures to suit the philanthropic needs of charity trustees or donors, and advise on how to make cross-border donations in a tax-efficient manner.
US/UK Tax Advice Publications
Testimonials
"[Collyer Bristow] advises on domestic and international wealth planning and is recognised for [its] extensive expertise in complex structuring with a significant multi-jurisdictional element"
Chambers & Partners, 2021
US/UK Tax Advice insights
Podcasts
Take it on trust (Part 2)Take it on trust (Part 2)
Listen now
Podcasts
Take it on trust (Part 1)Take it on trust (Part 1)
Listen now
Podcasts
The Average American – what should they know? (Part 2)The Average American – what should they know? (Part 2)
Listen now
Shorter Reads
Should I protect my finances ahead of US and UK elections?Should I protect my finances ahead of US and UK elections?
Read more
Podcasts
The Average American – what should they know? (Part 1)The Average American – what should they know? (Part 1)
Listen now
Podcasts
The Christmas Special!The Christmas Special!
Listen now
Podcasts
State of mind or question of fact? (Part 2)State of mind or question of fact? (Part 2)
Listen now
Podcasts
State of mind or question of fact? (Part 1)State of mind or question of fact? (Part 1)
Listen now
Podcasts
Planning Across the Pond (Part 2)Planning Across the Pond (Part 2)
Listen now
Podcasts
Planning Across the Pond (Part 1)Planning Across the Pond (Part 1)
Listen now
Podcasts
Jumping across the Atlantic?Jumping across the Atlantic?
Listen now
Podcasts
American Philanthropy (Part 2)American Philanthropy (Part 2)
Listen now
Need some more information? Make an enquiry below.
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