US/UK Estate Planning

Estate planning for clients with US connections requires specialist advice in order to avoid the numerous pitfalls that exist for the unwary. We have a team of specialist lawyers who frequently advise US taxpayers moving to or already living in the UK on their transatlantic tax issues.

Our specialist team of US/UK estate planners aim to find integrated solutions to the complicated issues caused by an exposure to UK and US taxes in a cost efficient and pragmatic manner.

We work closely with US advisors where necessary and advise on issues that include:

  • Putting in place Wills that are tax efficient in both the US and the UK.
  • Ownership solutions associated with the limited capital gains that can be made on the sale of a residential property before capital gains tax become payable in the US.
  • The UK tax implications of moving to the UK and techniques for mitigating tax liabilities.
  • Advice in relation to any trusts of which a US taxpayer is a settlor, trustee or beneficiary together with techniques for mitigating tax liabilities.
  • The UK implications of setting up a revocable trust (also known as a Living Trust) during lifetime.
Michelmores LLP provides 'City-standard advice' on US-UK cross-border IHT issues
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Recent experience

  • Advising wealthy couples where one spouse is a US person and the other spouse is a non-US person on the signing of tax efficient wills incorporating Qualified Domestic Trusts (QDOT) and generation skipping tax provisions.
  • Advising US citizens who have set up various trusts of significant value for the benefit of their children on the implications of their proposed relocation to the UK if they remain trustees of the trusts together with advice on remittance basis planning.
  • Advising a family on the restructuring of the ownership of their matrimonial home in order to avoid a charge to US capital gains tax on a proposed sale.
  • Advising a US citizen who is not resident or domiciled in the UK on the tax efficient structuring of their Will for the benefit of a branch of the family that live and work in the UK.
  • Advising the trustees of a family trust about the tax consequences of a beneficiary moving to the US and agreeing the action that needed to be taken to mitigate the new tax liabilities.