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.

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.

The most common questions we are asked and the areas on which we provide advice include:

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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-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.

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.

Mixed US/UK Marriages

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.

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.

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.

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.

Mixed US/UK Marriages

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.

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.

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.

“[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