Individuals with personal and financial connections in both the US and the UK need to navigate two very different and complex tax regimes. It is essential for them to obtain integrated advice in relation to their tax exposure and reporting obligations. It is, therefore, vital for their advisors to have a clear understanding of the interaction between the two regimes in order to plan effectively.
Forsters’ Private Client group has a team of specialist UK lawyers who are experienced in advising clients on US/UK cross-border matters, including personal tax, trust and estate planning. The team has 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 clients’ existing US advisors, or with selected firms with which we have well established relationships, in order to provide clients with integrated US/UK advice. Members of the US/UK team travel to the US regularly to meet clients and intermediaries there.
Our US/UK areas of expertise include:
- Estate planning advice and drafting wills for clients with exposure to both UK inheritance tax and US estate taxes.
- Pre-residence tax advice for US persons moving to the UK.
- Advice to US persons on structuring the acquisition and ownership of UK residential property.
- Advice on the characterisation of US revocable trusts for UK tax purposes.
- Advice on mitigating double tax risks associated with trusts that have US and UK tax connections.
- Advice on the creation of “excluded property trusts” for US persons to protect their non-UK assets from UK inheritance tax.
- Advice on gift planning for US persons using family limited partnership structures (where UK inheritance tax precludes the use of trusts).
- Advice on the creation, use and tax treatment of life insurance trusts for UK resident US persons.
- Advice on tax-efficient charitable giving for clients with a dual exposure to US and UK taxation.
- Advice to UK resident individuals on mitigating the risk of double taxation on income from US LLCs.
- Advice on cross-border restructuring of private businesses with entities that are resident in both the UK and US.
The US and the UK are separated by the vast and tumultuous waters of the Atlantic Ocean. Those with connections to both countries will often find themselves rowing against the tide between two very different and complex regimes. With the right specialist advice, they can navigate the cross-border challenges safely and make the best use of planning opportunities.
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