US estate tax and UK inheritance tax, planned as one picture
The US taxes estates and gifts; the UK charges inheritance tax. For US–UK cross-border families the two overlap in ways that can double up or leave gaps — planned together under the US–UK estate & gift tax treaty, they don't have to.
Which system reaches your estate
What decides whether US estate tax, UK inheritance tax, or both, apply.
- DomicileUK inheritance tax reaches your worldwide estate if you're UK-domiciled or deemed-domiciled.
- CitizenshipUS estate and gift tax follows US citizens and green card holders on worldwide assets.
- SitusWhere an asset sits can pull it into a system even for non-citizens and non-doms.
- TreatyThe US–UK estate & gift tax treaty relieves double taxation on death.
- GiftsUS gift tax and UK lifetime gifting rules, coordinated across both.
What families say about planning their estate
I am American and my wife is British, and our home in Surrey is in joint names. Taxule explained that gifts between us are treated differently by the IRS and by HMRC, then worked with our solicitor so our wills and our gifting plan hold up in both countries.
I have lived in New York for twenty years but still own a flat in Bath and a US brokerage account. They mapped which assets US estate tax could reach and which UK inheritance tax could reach, and showed me how the treaty relieves the overlap. For the first time I understand my real exposure.
When my father died in Pennsylvania I became his executor from here in York. The team worked alongside the US attorney and my own solicitor, handled the US estate filings and made sure the UK side was reported properly, so the family was not taxed twice on the same assets.
Who this service is for
Americans living in the UK
US citizens here whose estate and lifetime gifts still fall under US rules, even while UK assets bring UK inheritance tax into the picture too.
Brits living in the US
UK domicile can persist long after moving, and US estate tax can apply to US assets regardless — leaving exposure on both sides.
US-UK cross-border families
Spouses, children or heirs split across both countries, where one estate can trigger tax under two different regimes at once.
Families with assets in both countries
Property, investments or accounts on both sides of the Atlantic, where situs rules decide which system reaches each asset.
Moving to the UK and planning ahead? Start with Pre-arrival & FIG planning.
Situs: where your assets are decides who taxes them
US estate tax and UK inheritance tax reach different assets depending on where they sit. Pick an asset to see the general pattern — an illustration, not advice.
US-situs vs UK-situs, on death
A rough guide to which system reaches each asset, for a US citizen domiciled in the UK.
What's included
You get a written scope first, setting out exactly what we map and plan across both systems.
Estate tax & IHT mapped
US estate and gift tax and UK inheritance tax set out together, so you see the whole exposure in one picture.
Domicile & deemed-domicile
Your UK domicile and deemed-domicile position worked out — it drives how much of your estate UK IHT can reach.
The US–UK treaty
The US–UK estate and gift tax treaty applied to your actual facts to relieve double taxation on death.
Where your assets sit
Situs rules decide which country taxes each asset — US-situs assets can trigger US estate tax even for non-citizens.
Lifetime gifting
US gift tax and UK lifetime gifting coordinated, so a gift on one side doesn't cost you on the other.
Alongside your solicitor
We're the cross-border tax layer, working with your solicitor so your will and the tax plan hold together.
How US and UK death taxes interact
The rules that decide what your estate owes, and where.
The US taxes citizens worldwide
US estate and gift tax follows US citizens and green card holders on their worldwide assets, with a large lifetime exemption that's set each year.
The UK taxes by domicile
UK inheritance tax reaches your worldwide estate if you're UK-domiciled or deemed-domiciled; otherwise usually only UK assets.
Non-citizens and US-situs assets
US real estate and US shares can trigger US estate tax even for non-citizens, often with a much lower exemption than citizens get.
The spousal trap
The unlimited spousal exemption doesn't automatically apply where a spouse isn't a US citizen — planning is needed to avoid a surprise bill.
The treaty relieves overlap
Where both systems reach the same asset, the US–UK estate & gift tax treaty gives relief — but only when read against your facts.
Gifts have their own rules
US gift tax applies during life; the UK uses seven-year potentially-exempt transfers. The two need coordinating, not treating separately.
Why Taxule for cross-border estate planning
Because a cross-border estate needs both systems read together, against your real facts.
Both systems, one team
US estate/gift tax and UK IHT mapped together, so nothing is double-counted or missed.
Facts, not templates
Domicile, situs and the treaty applied to your actual assets and family — not a generic checklist.
Beside your solicitor
We handle the cross-border tax; your solicitor handles the will. The two are coordinated.
How estate planning works with us
- 1
Map the estate
We set out the assets, where they sit and which system reaches each part.
- 2
Coordinate the two regimes
We read the treaty and the domicile position against your facts, not a template.
- 3
Set a plan
Structuring, gifting and documentation designed to hold together on both sides.
Cross-border estate questions
Straight answers to what cross-border families ask most.
I'm American but I've lived in the UK for years — which system applies?
Potentially both. Your domicile and deemed-domicile position, and where your assets sit, drive whether US estate tax and UK inheritance tax each reach your estate. Establishing that is the first thing we do.
Can the US–UK treaty stop double taxation on death?
The US–UK estate & gift tax treaty is designed to relieve double taxation on death, but it has to be read against your specific facts — domicile, situs and asset type. We work through it rather than assume an outcome.
Do I owe US estate tax if I'm not a US citizen?
You can. US-situs assets — such as US real estate or US shares — can trigger US estate tax even for non-citizens, often with a much lower exemption. We identify that exposure and plan around it.
Does UK inheritance tax apply to my worldwide estate?
If you're UK-domiciled or deemed-domiciled, UK IHT can reach your worldwide estate; if not, usually only UK assets. Your domicile position is what decides it, which is why we establish it first.
Do you write the will?
No — we're the cross-border tax layer and coordinate closely with your solicitor, who handles the will itself.
