Wealth across two systems? Plan the estate as one picture.
The US taxes estates and gifts; the UK taxes inheritance. For cross-border families the two systems overlap in ways that can double up or leave gaps — planned together, they don't have to.
Two death-and-gift regimes, one family
US estate and gift tax and UK inheritance tax reach different people and different assets — domicile, residence and where assets sit all change the answer. Left uncoordinated, a cross-border estate can face exposure on both sides at once; the treaty and careful structuring are what bring it back into line.
Both sides, under one roof
Three steps, one team
Map the estate
We set out the assets, where they sit and which system reaches each part.
Coordinate the two regimes
We read the treaty and the domicile position against your facts, not a template.
Set a plan
Structuring, gifting and documentation designed to hold together on both sides.
The things clients ask first
I'm American but I've lived in the UK for years — which system applies?
Potentially both. Your domicile position and where your assets sit drive the answer, and establishing that is the first thing we do.
Can the treaty stop double taxation on death?
It's designed to help, but it has to be read against your specific facts. We work through it rather than assume an outcome.
Do you write the will?
No — we're the cross-border tax layer and coordinate closely with your solicitor, who handles the will itself.
Let's map the estate across both sides.
A free consultation, no obligation. Tell us how the family and its assets are spread and we'll map what each system reaches — with a fixed price before any work begins.
