US Private Wealth and Tax

US citizens resident in the UK face acute challenges to manage their potential exposure to double taxation and ensuring that their estate plans are compatible both sides of the Atlantic. Couples who are subject to both UK inheritance tax and US estate tax have specific estate-planning needs. If one spouse or civil partner is a US person whilst the other is not, careful planning is required to manage the vagaries of dual tax exposure and of potential citizenship and domicile mismatch. Our team of specialist US and UK qualified tax and trusts lawyers provide an integrated US / UK estate planning service.

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We regularly advise on and draft complex onshore and offshore trusts and wills for international clients who are US citizens, including the use and creation of life insurance trusts, trusts that qualify as US Foreign Grantor Trusts and advise on succession planning structures with long-term governance objectives. 

We advise settlors, beneficiaries and trustees on the US federal tax implications of trust structures with a non-US component, including:

•  Foreign grantor trust planning;
•  Use of trusts to hold US-sited investments;
•  Trust structuring for US settlors (for both US federal tax and succession planning purposes).

We assist US citizens with their pre-UK immigration tax planning.

We  provide US federal income tax advice in relation to relocating to the US. We advise on the most beneficial US visa categories for immigration (/services/immigration) and tax purposes, providing comprehensive application support and overcoming ineligibilities and refusals.

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We regularly draft estate plans, integrated Wills and revocable trusts for US citizens and have extensive experience in cross border estate administration and probate. We regularly assist US lawyers to apply for UK Grants of Probate.  We are authorised providers of the Medallion Guarantee Stamp which is essential to the transfer of US securities.

We advise on the US federal tax implications on the death of a non-US settlor (post grantor planning).

We help you navigate the tax implications of relinquishing US residency/Green Card status or citizenship. We can facilitate  the immigration process, including preparation for exit interviews, the in-person oath, and assistance with all necessary documentation.

We advise on addressing historic US federal tax non-compliance. Advising individuals, trust companies, and fiduciaries concerning US persons' reporting obligations in relation to non-US entities and non-US trust structures.