Rebecca Anstey

Rebecca Anstey

Rebecca is a Senior Associate in our Private Client team.

She acts for both UK‑based and international clients, advising individuals, families, and trustees on a broad range of estate planning and taxation matters.

Rebecca’s work includes the preparation of wills and lasting powers of attorney, advising on related tax planning, and trust structuring and administration. She has experience advising on residence and domicile and on US/UK cross‑border matters.

US/UK

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Expert advice on your US/UK cross-border matters

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
  • 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
  • Disputes involving trusts with US and UK connections
  • 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
  • Putting in place UK lasting powers of attorney
  • Application and enforcement of US powers of attorney in the UK
  • Applications for deputyships (agreed or contested)
  • Applications to the Court of Protection in respect of property and financial affairs or cross-border relocation (agreed or contested)
  • Administration of international estates that include US and UK assets
  • Obtaining UK grant of probate for administration of UK estate (including under US wills)
  • Will and estate administration disputes, and financial provision claims involving US and UK estates
  • Tax-efficient charitable giving where these is a dual exposure to US and UK taxation.
  • 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
  • International pre-nuptial and post-nuptial agreements for spouses who have connections with or are living between the UK and US
  • Preparation of Cohabitation agreements outlining the rights and responsibilities of each partner during cohabitation and in the event of the breakdown of a relationship
  • Collaborating with our network of professional advisors to resolve cross-border financial issues on divorce or separation, including in respect of enforcement issues
  • Resolving issues relating to children in the event of divorce or separation, such as relocating or wrongfully retaining a child in the UK or the US

Your guide to US-UK cross-border planning

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Navigate the Atlantic with ease

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Emma Jones

Emma Jones

Emma specialises in UK probate and estate administration and is a Senior Associate in the firm’s Private Client team.

Her expertise ranges from applying for all types of English grants of representation to advising as to succession rules where there is no valid will to undertaking domicile reviews so that succession and tax rules are correctly applied. She has extensive knowledge of HMRC’s disclosure and valuation principles and regularly assists personal representatives with their Inheritance Tax reporting obligations. She also deals with all ancillary probate matters including post-death tax planning, such as advising on and preparing deeds of variation, and the administration of will trusts.

Emma acts for both UK and non-UK personal representatives and most of her work involves a cross-border element. She has extensive experience in co-ordinating the administration of estates that span multiple jurisdictions ensuring that joined up tax advice is received. She has particular interest in administering estates with US connections and regularly works with US personal representatives and advisors.

Emma has recently completed the STEP Advanced Certificate in Cross-Border Estates.

Lucie Bennett

Lucie Bennett

Lucie is a Senior Associate in the firm’s Private Client team where she acts primarily for international clients on a broad range of estate planning and personal taxation matters, including tax and succession planning, the preparation of wills and incapacity documents, and broader trust matters.

She has a particular focus on advising high net worth clients with US connections, such as in respect of the development and implementation of integrated estate plans. She assists US-connected individuals and trustees navigate the interplay between the US and UK systems, including advising on the application of the US/UK treaties to mitigate the risk of double taxation.

Lucie advises on the establishment of trusts for succession planning and asset protection purposes, and on the UK treatment of existing structures, which may involve trusts, partnerships and corporate vehicles.

She also provides advice to clients considering relocating to the UK to ensure that their affairs are arranged in a tax efficient manner before becoming UK resident. She has experience providing immigration advice to high net worth individuals using the (previous) UK Tier 1 (Investor) Visa and the UK “Spouse Visa”. She has also assisted clients with subsequent applications for Indefinite Leave to Remain in the UK and naturalisation as a British citizen.

Hannah Mantle

Hannah Mantle

Hannah is a Partner in the Trust and Estate Disputes team and is recognised for her expertise in domestic and international private client disputes, including contentious probate, trust disputes, Court of Protection and capacity matters.

She combines emotional intelligence with technical expertise to advise clients on sensitive and complex matters. Taking a proactive and strategic approach to disputes, she works to achieve the best possible outcome for her clients. Hannah also recognises the value of mediation and other forms of alternative dispute resolution where these align with her clients’ objectives. She acts for a wide range of onshore and offshore clients, including professional and lay fiduciaries, beneficiaries and other parties, across the full spectrum of private wealth disputes.

Hannah values effective collaboration with clients, colleagues across Forsters and professionals in other jurisdictions. She regularly coordinates cross-jurisdictional teams on international matters, as well as multidisciplinary teams advising on both contentious and non-contentious issues alongside colleagues in the Private Client, Family and Property teams.

Ranked in Chambers High Net Worth Guide 2024 and praised in The Legal 500 2023 for her ‘excellent litigation management skills’, Hannah is also described in the directories as ‘brilliant’ and ‘practical, collaborative and sensible’. She is a full member of ACTAPS, STEP and AIJA, and serves as Deputy Chair of STEP’s Contentious Trusts and Estates Special Interest Group.

Charles Miéville

Charles Miéville

Ranked in Chambers High Net Worth Guide 2025, Charles is noted as being ‘highly regarded by clients and fellow lawyers in the industry’ and described by clients as ‘calm, collected and highly knowledgeable’ and ‘a very capable individual that clients can rely on and trust’. In The Legal 500, he is recognised for his work with private individuals on residential acquisitions and disposals. He is also recognised as a Top Recommended Lawyer in Spear’s 500 2026.

As a Partner in the Residential Property team, Charles specialises in the acquisition, disposal and financing of prime residential property, primarily in Central London. He advises a broad international client base, including many clients based in the Middle East and the United States, and helps them navigate the complexities of English property law. He also advises on Sharia-compliant financing arrangements.

Charles values long-term client relationships and advises on a wide range of matters beyond individual transactions. Clients also benefit from his extensive network of professional contacts, including interior designers, architects, project managers and school advisers.

He has strong relationships with both selling and buying agents and regularly visits properties to gain first-hand insight into the assets involved. This enables him to provide informed advice throughout a transaction and helps build effective working relationships with agents and other advisers involved in the process.

George Mitchell

George Mitchell

Recognised as a Recommended Tax Lawyer in the latest Spear’s Tax & Trust Indices, George advises internationally mobile individuals and families on their exposure to UK taxation and the development and implementation of cross-border estate plans.

As a Partner in the Private Client team, George draws on his early career experience as a corporate tax lawyer to provide practical advice on complex legal and tax matters. He has particular expertise in helping individuals and families structure their ownership interests in businesses and develop succession plans that reflect both personal and commercial objectives.

His familiarity with US tax rules and succession planning structures enables him to advise individuals, families and trustees with US connections on the interaction between the UK and US tax regimes. This often includes helping clients address cross-border planning issues and mitigate the risk of unintended tax consequences.

George’s clients include entrepreneurs, multinational business owners, executives, family offices and family trusts.

Since 2023, George has led Forsters’ Green Impact Group, helping to raise environmental awareness and engagement across the firm. Initiatives have included organising the annual River Lea clean-up, collaborating with the Working Parents and Carers Network on a spring art competition for children connected to the firm, and partnering with the HR team to support gardening activities at the firm’s former charity partner, the Marylebone Project, as part of its wellbeing programme.

Xavier Nicholas

Xavier Nicholas

Recognised as one of eprivateclient’s “50 Most Influential” private client professionals and one of Legal Week’s Private Client Global Elite, Xavier leads Forsters’ award-winning Private Client practice.

As Head of Private Client, Xavier advises individuals, families and trustees in the UK and internationally on personal taxation, trust and estate planning. He has particular expertise in the establishment, taxation and operation of cross-border asset-holding structures, including companies, partnerships, trusts, private trust companies and foundations.

Xavier is a trusted adviser to international families and has significant experience advising families, trustees and family offices with business interests. This includes advising on family charters, family constitutions and wider family governance arrangements.

For overseas clients, Xavier advises on pre-arrival tax planning for individuals relocating to the UK and succession planning for those with assets across multiple jurisdictions. He also frequently advises clients with US connections on the UK aspects of US-UK estate planning and the interaction between the UK and US tax regimes.

Jeremy Robertson

Jeremy Roberston

Noted in The Legal 500 2024 as ‘excellent, extremely approachable, knowledgeable and, importantly, likeable’, Jeremy is a Partner in the Private Client team. He has extensive experience advising UK and international clients on personal taxation, succession planning and family governance. He works closely with entrepreneurs, business owners, executives and their families on capital taxation, corporate and trust structuring, and the development and implementation of estate plans for both UK and non-UK resident individuals.

Jeremy is known for providing clear and concise advice, helping clients achieve their objectives in a tax-efficient manner.

He has particular expertise in the structuring options and tax implications associated with acquiring UK property. He regularly advises on UK and offshore tax planning, including the taxation of excluded property trusts and trust administration matters.

Jeremy also advises extensively on family office matters, supporting both established family offices and clients looking to create new family office structures. He has particular expertise in family governance, including the establishment of private trust company structures and the preparation of family charters and other governance documents.

Since 2022, Jeremy has co-led the firm’s Community and Charity Committee alongside Michael Armstrong. In this role, he supports a range of community engagement and fundraising initiatives across the firm.

Rosie Schumm

Rosie Schumm

Described by the Legal 500 as ‘the ultimate family lawyer’, Rosie is a Partner in the Family team. She specialises in complex divorce, separation and children cases, often with an international dimension.

With a global network of contacts, Rosie’s international profile and expertise make her a ‘go to’ matrimonial lawyer for clients with a global footprint. Rosie is experienced in dealing with the impact of divorce and separation on international wealth, including offshore assets and trusts, family businesses, private equity, property portfolios and super prime assets. She regularly acts for clients who are in the public eye, working to ensure privacy and discretion throughout.

She works closely with Forsters’ Private Client and Disputes teams, advising on the use of cross-border nuptial agreements for succession planning. She also has expertise in dealing with same sex divorce, surrogacy and alternative conception work for all types of individuals and families, with a particular interest in children cases involving special needs.

Rosie cuts through the complexity of the law to provide clients with a clear and strategic way forward, while providing sensitive and empathetic support during what can be a very difficult time. She will take a direct, forceful and dynamic style when beneficial for her client. Her holistic approach includes providing access to a supportive team including therapists, private bankers, reputation advisors and security experts.

Emma Gillies

Emma Gillies

Described in Chambers UK 2024 as “exceptionally knowledgeable and extremely likeable”, Emma is a Partner in the Private Client team, specialising in personal tax and wealth planning matters.

Ranked in the latest Chambers High Net Worth Guide and recognised as Top Recommended in Spear’s 500, Emma advises high net worth clients on cross-border tax and estate planning, with a particular focus on American individuals and families with connections to the UK.

Emma has extensive expertise in the creation and use of trusts as a means of succession planning and preserving family wealth. She also advises on alternative wealth structures where trust planning is not appropriate.

She has deep knowledge of the UK’s residence rules, the residual impact of the former remittance basis regime, and the tax implications of acquiring UK property, including the range of available structuring options.

Emma leads a team that advises clients with US connections, including those relocating to the UK for the first time. Her familiarity with US personal tax and wealth planning strategies enables her to help clients and their advisers navigate the interaction between the US and UK regimes. Much of this work involves advising on the application of international treaties to mitigate the risk of double taxation.

Dickon Ceadel

Dickon Ceadel

Ranked as an ‘Up‑and‑Coming’ Partner in Chambers UK and as a ‘Next Generation Partner’ in The Legal 500 UK, Dickon is highlighted for his ‘top client care skills as well as his brilliant legal knowledge’ and ‘intellectual firepower’.

Dickon has wide‑ranging experience of resolving ‘big money’ financial disputes on divorce and relationship breakdown. He specialises in preparing and negotiating both domestic and international pre‑ and post‑nuptial and cohabitation agreements. He is renowned for his knowledge of parental rights and obligations, and private child law matters, including child abduction, internal and international child relocation, and surrogacy. His cases often involve complex assets and multiple jurisdictions.

He ‘is very astute’ and ‘exudes reassurance’, providing first‑class support to clients. Dickon works hard to get to know people and to understand their priorities in order to achieve their desired outcome. He is known for taking a firm but fair, pragmatic and constructive approach to resolving issues. Having represented numerous high‑profile clients, he is acutely aware of the importance of discretion.

Dickon is a member of Forsters’ US/UK and sports law groups.