US/UK
When you have personal and financial connections in both the US and the UK, you are forced to navigate two very different and complex tax regimes. Where there are transatlantic ties, whether through the location or origin of assets or family members, it is essential to obtain integrated advice in relation to tax and reporting requirements. In order to plan effectively, it is vital to receive guidance from advisors that have a clear understanding of the interaction between the two regimes.
Forsters’ Private Wealth practice has a team of specialist UK lawyers who are experienced in advising on US/UK cross-border matters, including personal tax, trust and estate planning. We have a strong understanding of US tax issues and how they interact with UK taxation.
Our deliberately independent model means that we have the flexibility to work either with your existing US advisors, or with selected firms with which we have well established relationships. Our US/UK team travel to the US regularly to meet clients and intermediaries.
We can help with the following US/UK issues:
Estate and succession planning
- Drafting wills and providing integrated estate planning advice that takes account of exposure to UK inheritance tax and US estate taxes
- Formation, administration and taxation of succession planning structures for US-connected families, including trusts and family partnerships
- Tax-efficient structuring of US estate plans for the benefit of UK resident beneficiaries
- Creation and use of life insurance trusts for UK resident US persons
Trusts
- Ascertaining the character of US revocable trusts for UK tax purposes
- Mitigating double tax risks associated with trusts that have US and UK tax connections
Moving from the US to the UK
- Pre-arrival tax planning
- Acquiring UK residential property and tax-efficient holding structures
- UK immigration
- Review of nuptial agreements
- Ongoing cross-border tax advice with reference to US-UK double tax treaties
Incapacity
- Putting in place UK lasting powers of attorney
- Application and enforcement of US powers of attorney in the UK
Probate and estate administration
- Administration of international estates that include US and UK assets
- Obtaining UK grant of probate for administration of UK estate (including under US wills)
Charitable giving
- Tax-efficient charitable giving where these is a dual exposure to US and UK taxation.
Business
- Cross-border restructuring of private businesses with entities that are resident in both the UK and US
- Mitigating the risk of double taxation on receipt of income by UK residents from US LLCs