Your estate touches two tax systems. Plan it as one.
Own assets, trusts, or family wealth on both sides of the Atlantic, and both the US and UK will want a share when it passes on. Without coordination, the same money can be taxed twice — or a plan that works perfectly in one country creates a problem in the other. There's a way to structure it so it doesn't.
Two estate tax systems, one family
The US taxes based on citizenship and situs, the UK on domicile — and the thresholds, exemptions and rules for trusts differ entirely between the two. Get the interaction wrong, and a well-meant gift or a straightforward inheritance can trigger tax nobody planned for. Get it right, and treaty relief plus careful structuring keep double taxation off the table.
Both sides, under one roof
Three steps, one team
Map the estate
We build a full picture of assets, trusts and beneficiaries on both sides, and flag where the two systems clash.
Structure it properly
We design gifting, trust and ownership structures that hold up under both US and UK rules — not just one.
Keep it current
Tax law and family circumstances both change. We review the plan as they do, so it keeps working.
The things people ask first
Will my estate really be taxed twice?
Not if it's structured properly. The US–UK tax treaty provides relief in most cases, but only if the right filings and elections are made on both sides.
Do UK trusts cause problems for US beneficiaries?
They can. US tax law treats many UK trusts very differently from how the UK does, which creates reporting obligations and sometimes unexpected tax. We check this before it becomes a surprise.
What if our family's wealth is spread across many entities?
That's normal for HNW families — multiple entities, currencies and jurisdictions. We build one coordinated view so nothing falls through the cracks.
Let's map your two sides.
A free consultation, no obligation. We'll look at your US and UK estate position together and tell you exactly what you need — and what it costs, up front.
