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Private Client Services

US/UK Private Client Services

Our US/UK Private Client Services Team provides specialist UK advice to US clients and to those with US connections.

We pride ourselves on delivering technically excellent advice that is also practical and tailored to our clients’ individual needs and circumstances.

We are supported by a strong network of trusted lawyers and other professionals across the US and are also happy to work with our client’s existing advisers to provide integrated multi-jurisdictional solutions, for example in relation to:

  • Estate planning for US citizens
  • The use of US trusts and foreign trusts, such as US revocable trusts and excluded property settlements
  • Pre-immigration planning and pre-deemed domicile planning
  • Double taxation mitigation, including advice on UK / US tax treaty planning

Work examples:

  • Advice on UK implications of sole trustee and beneficiary of a US trust becoming UK resident, including advice on the application of the UK / US tax treaty to the mis-match of UK and US tax liabilities
  • Pre-immigration planning for a couple comprising a US citizen and a UK returning former domiciliary, including advice on the statutory residence test and the timing of becoming UK resident, advice on the UK domicile rules, review of their US revocable trust and other US trusts, the implications of the sale of their US property and acquisition of a UK property, advice on the gifting of assets between spouses, the setting up of an excluded property trust.
  • Advice for a couple comprising a US citizen and a returning former domiciliary moving to the UK on the management of US bank accounts, including advice in relation to community property and mutual funds.
  • Advice to UK resident couple, comprising a US citizen and a UK domiciliary on their exposure to inheritance tax on the first death and mitigation options.
  • Advice to a deemed UK domiciled US citizen on the UK treatment of her US revocable trust, involving advice on the nature of the trust for UK purposes, events which may change its status, and recommendations for changes to structure.
  • Advice to a UK domiciled US citizen on his exposure to UK inheritance tax and US estate tax, including advice on establishing a US revocable trust, the statutory residence test and losing his UK domicile status, and making testamentary gifts to UK and US charities
  • Advice to a UK citizen living in the US on domicile, and on the structuring of the funding to his UK resident daughter to acquire UK property.
  • Advice to a US citizen couple living in the UK on the UK implications of their US revocable trust, establishing a UK excluded property settlement, the considerations around protected settlements and the availability of tax credits, and pre-deemed domicile planning.
  • Preparation of UK Wills for US citizens with UK assets.
  • Advice to a UK domiciled US citizen on the tax implications of her ownership and control of a US business and on inheritance tax mitigation through the gifting of assets.
  • Advice to a UK resident beneficiary of a US revocable trust, involving the analysis of the nature of the Trust and consequent UK tax implications.
  • Advice on the UK tax implications of winding up a US LLC holding UK residential property, held by a Colorado trust.  Including an analysis of the UK treatment over the inter-generational lifetime of the trust from ownership by the original grantor, introduction of the 2018 Colorado Trust Code, and transition to an irrevocable trust for the next generation.
  • Cross-disciplinary project advising on the expansion of a US/Mexican trading business into UK, including immigration and personal estate tax planning and property acquisition for the CEO.
  • Pre-residency planning for Texan domiciled clients, including advising on statutory residence, domicile, formerly domiciled resident rules, remittance basis tax planning and US/UK estate tax treaty.
  • Advising a US/UK couple on Wills and LPAs, including liaising with their US advisers to coordinate Wills across the two jurisdictions, considering charitable giving and planning with pensions as part of the Wills exercise.
  • Advising a US/UK couple on gifting interests in their UK property from the US spouse to the non-US spouse, to maximise CGT efficiency whilst ensuring compliance with US spousal gifting rules.

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For general enquiries please call +44 (0)808 169 4320 or send a message from our Contact us page.