US / UK advice

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 tax and trust 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 and are also able to communicate readily by via video conference.

Our US/UK areas of expertise include:

  • drafting wills (and related estate planning documents) for clients with exposure to both UK inheritance tax and US estate taxes
  • advising on the creation of excluded property trusts for US citizens to protect their non-UK assets from UK inheritance tax
  • trust planning for non-US individuals with US family members
  • advising US citizens (or green card holders) who are UK resident settlors and/or beneficiaries of trusts on managing their potential exposure to double taxation
  • gift planning for US citizens using family limited partnership structures where UK inheritance tax considerations preclude the use of trusts
  • advising UK resident individuals on mitigating the risk of double taxation on income from US LLCs
  • advising on the use and creation of life insurance trusts for US citizens who are living in the UK
  • advising US citizens on their ability to use the EU Succession Regulation to exercise their rights to avoid “forced heirship” rules that would otherwise apply to assets held in many continental European jurisdictions
  • pre-UK immigration planning for US citizens
  • establishing dual-qualified charitable entities that qualify for favourable tax treatment in both the UK and US.

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"'The team is extremely solution-oriented and has a great capacity to summarize and digest complex multi-jurisdictional estate matters. The team has a much better understanding of the common civilian law issues than most of the other English firms."
The Legal 500, 2020