Inheritance tax planning solicitors
Our inheritance tax planning solicitors offer peace of mind when passing assets to the next generation. Whether your assets are based in a single country or spread around the world, we can help with inheritance and estate tax planning so that the authorities do not take more than their fair share.
We advise many of the world’s most successful families on how to pass wealth to future generations in the most tax‑efficient way possible.
Cross‑border inheritance tax considerations
Planning across jurisdictions
Inheritance tax planning often becomes more complex where families, assets or obligations span more than one country.Perhaps you are a US-UK couple looking to plan your estate, which includes assets in both jurisdictions. Perhaps you are not resident in the UK but are facing a double tax bill on an inheritance there. Perhaps you are UK resident and domiciled but wish to make lifetime gifts to members of your family.
Each of these situations raises different inheritance planning considerations, particularly where more than one tax system may apply.
International inheritance tax planning
Structuring assets and managing exposure
Whether your wealth is based entirely in your country of origin or is spread widely around the world, we can assist with inheritance tax planning. We use flexible trusts, family limited partnerships and limited liability companies to help support the orderly transfer of wealth to the intended beneficiaries, while seeking to ensure that the government does not take more than its fair share.Our international reach means that we are frequently asked to assist with cross-border cases where assets may be taxed twice. We also advise where penalties have been incurred.
Track record
Advising a cross border couple on complex estate and succession planning
Our team advised a cross border couple on complex estate and succession planning involving divergent domicile, citizenship and tax profiles, including addressing UK inheritance tax exposure, US estate tax risks and the absence of spousal exemptions, alongside assets spanning the US, UK and offshore jurisdictions. The work involved restructuring asset ownership, mitigating forced heirship constraints under Scottish law, and designing a coherent succession framework to provide for the surviving spouse while preserving long term inheritance for children (including from prior relationships), supporting family governance and the intergenerational transfer of significant business and property interests.
Brazilian born ultra high net worth individual
We advised a Brazilian born ultra high net worth individual on cross border estate and succession planning in light of anticipated reforms to the UK non dom regime, with a particular focus on mitigating inheritance tax exposure across a multi jurisdictional asset base. Our work included reviewing and restructuring offshore trust and corporate holdings ahead of new UK rules, developing tax efficient strategies for the preservation and transfer of wealth, and advising on carried interest and trust planning, culminating in a flexible, forward looking succession framework designed to support long term family governance and efficient intergenerational wealth transfer under the evolving UK tax landscape.
UK‑resident ultra‑high‑net‑worth business owner
Advised a UK‑resident ultra‑high‑net‑worth business owner on complex cross‑border inheritance and succession planning following changes to Business Property Relief, including the design and implementation of a bespoke trust and holding structure to preserve control of significant operating businesses while enabling tax‑efficient generational transfer. The work involved detailed residence planning to facilitate relocation alongside the restructuring of personal and corporate assets, and the creation of a robust succession framework incorporating tailored governance mechanisms to address sensitive family dynamics and ensure the long‑term stewardship of substantial business interests.
Executors of multi-jurisdictional estate
Advised the executors of a complex multi-jurisdictional estate on its administration and securing Business Property Relief from inheritance tax on private family company shares.
Post death tax planning
Following the unexpected death of the principal of a large trading business, we advised on post-death tax planning to maximize inheritance tax reliefs, both on death and on the death of the surviving spouse in due course. This has involved complicated tax, trust and corporate issues to avoid significant tax charges on the restructure and a number of clearance applications with HMRC.
Cross border wills
Advising a number of clients who are domiciled in India and Pakistan on the structure of their wills to maximize the possibility of tax treaties with the UK applying on death. This can protect UK assets from charges to UK inheritance tax notwithstanding the clients being UK deemed domiciled through long term residence.
Cross border wills
Advising a number of clients who are domiciled in India and Pakistan on the structure of their wills to maximize the possibility of tax treaties with the UK applying on death. This can protect UK assets from charges to UK inheritance tax notwithstanding the clients being UK deemed domiciled through long term residence.
Advising a cross border couple on complex estate and succession planning
Our team advised a cross border couple on complex estate and succession planning involving divergent domicile, citizenship and tax profiles, including addressing UK inheritance tax exposure, US estate tax risks and the absence of spousal exemptions, alongside assets spanning the US, UK and offshore jurisdictions. The work involved restructuring asset ownership, mitigating forced heirship constraints under Scottish law, and designing a coherent succession framework to provide for the surviving spouse while preserving long term inheritance for children (including from prior relationships), supporting family governance and the intergenerational transfer of significant business and property interests.
Brazilian born ultra high net worth individual
We advised a Brazilian born ultra high net worth individual on cross border estate and succession planning in light of anticipated reforms to the UK non dom regime, with a particular focus on mitigating inheritance tax exposure across a multi jurisdictional asset base. Our work included reviewing and restructuring offshore trust and corporate holdings ahead of new UK rules, developing tax efficient strategies for the preservation and transfer of wealth, and advising on carried interest and trust planning, culminating in a flexible, forward looking succession framework designed to support long term family governance and efficient intergenerational wealth transfer under the evolving UK tax landscape.
UK‑resident ultra‑high‑net‑worth business owner
Advised a UK‑resident ultra‑high‑net‑worth business owner on complex cross‑border inheritance and succession planning following changes to Business Property Relief, including the design and implementation of a bespoke trust and holding structure to preserve control of significant operating businesses while enabling tax‑efficient generational transfer. The work involved detailed residence planning to facilitate relocation alongside the restructuring of personal and corporate assets, and the creation of a robust succession framework incorporating tailored governance mechanisms to address sensitive family dynamics and ensure the long‑term stewardship of substantial business interests.
Post death tax planning
Following the unexpected death of the principal of a large trading business, we advised on post-death tax planning to maximize inheritance tax reliefs, both on death and on the death of the surviving spouse in due course. This has involved complicated tax, trust and corporate issues to avoid significant tax charges on the restructure and a number of clearance applications with HMRC.
Cross border wills
Advising a number of clients who are domiciled in India and Pakistan on the structure of their wills to maximize the possibility of tax treaties with the UK applying on death. This can protect UK assets from charges to UK inheritance tax notwithstanding the clients being UK deemed domiciled through long term residence.
US citizen buying UK property
Buying property in a different country can be more complicated between some jurisdictions and in particular for a US buyer in the UK. Our integrated US team in London working with our UK tax and property teams were able to assist our US client to buy the UK residential property, utilizing debt finance from his US trust structure. It was important to get the interplay between US and UK estate taxes right for him in light of him also becoming a UK tax resident, so we have advised on his broader estate planning too.
Advising a cross border couple on complex estate and succession planning
Our team advised a cross border couple on complex estate and succession planning involving divergent domicile, citizenship and tax profiles, including addressing UK inheritance tax exposure, US estate tax risks and the absence of spousal exemptions, alongside assets spanning the US, UK and offshore jurisdictions. The work involved restructuring asset ownership, mitigating forced heirship constraints under Scottish law, and designing a coherent succession framework to provide for the surviving spouse while preserving long term inheritance for children (including from prior relationships), supporting family governance and the intergenerational transfer of significant business and property interests.
Brazilian born ultra high net worth individual
We advised a Brazilian born ultra high net worth individual on cross border estate and succession planning in light of anticipated reforms to the UK non dom regime, with a particular focus on mitigating inheritance tax exposure across a multi jurisdictional asset base. Our work included reviewing and restructuring offshore trust and corporate holdings ahead of new UK rules, developing tax efficient strategies for the preservation and transfer of wealth, and advising on carried interest and trust planning, culminating in a flexible, forward looking succession framework designed to support long term family governance and efficient intergenerational wealth transfer under the evolving UK tax landscape.
US citizen buying UK property
Buying property in a different country can be more complicated between some jurisdictions and in particular for a US buyer in the UK. Our integrated US team in London working with our UK tax and property teams were able to assist our US client to buy the UK residential property, utilizing debt finance from his US trust structure. It was important to get the interplay between US and UK estate taxes right for him in light of him also becoming a UK tax resident, so we have advised on his broader estate planning too.
Brazilian family
Aided a Brazilian family with significant US commercial real estate holdings to restructure the ownership of this property to avoid US estate tax. We also devised arrangements for Brazilian residents to create legitimate structures that are protected from Brazilian taxation, permit efficient repatriation of capital to Brazil when needed and ensure optimal flexibility and family control to respond to changing needs and tax laws in the future.
Chilean businessman
Represented a prominent Chilean businessman to secure and sustain his assets for his US-born descendants by allowing him to avoid US estate tax and reduce his Chilean property tax payments using usufruct transactions.
An estate executor
One executor of a will came to us when he wanted to take action against his late spouse's solicitor. We were able successfully to argue that the solicitor had failed to effectively advise about US tax liabilities on the spouse's worldwide assets during the making of her UK will.
Brazilian born ultra high net worth individual
We advised a Brazilian born ultra high net worth individual on cross border estate and succession planning in light of anticipated reforms to the UK non dom regime, with a particular focus on mitigating inheritance tax exposure across a multi jurisdictional asset base. Our work included reviewing and restructuring offshore trust and corporate holdings ahead of new UK rules, developing tax efficient strategies for the preservation and transfer of wealth, and advising on carried interest and trust planning, culminating in a flexible, forward looking succession framework designed to support long term family governance and efficient intergenerational wealth transfer under the evolving UK tax landscape.
Brazilian family
Aided a Brazilian family with significant US commercial real estate holdings to restructure the ownership of this property to avoid US estate tax. We also devised arrangements for Brazilian residents to create legitimate structures that are protected from Brazilian taxation, permit efficient repatriation of capital to Brazil when needed and ensure optimal flexibility and family control to respond to changing needs and tax laws in the future.
Chilean businessman
Represented a prominent Chilean businessman to secure and sustain his assets for his US-born descendants by allowing him to avoid US estate tax and reduce his Chilean property tax payments using usufruct transactions.
Recent recognition
Our team
Stacy Choong
Partner | Singapore
Katie Graves
Partner | Hong Kong
Alex Chung
Partner | Hong Kong
Christina M. Baltz
Partner | New York
Edward A. Renn
Of Counsel | New York
Giulia Cipollini
Partner | Milan
Caroline Moss
Special counsel | London
Christopher King
Special counsel | London
Insight
Join the club
We have lots more news and information that you'll find informative and useful. Let us know what you're interested in and we'll keep you up to date on the issues that matter to you.
Get in touch
Our website will give you a flavor of the advice we provide - if you would like to talk to us for more information, please contact our client services team who will be happy to assist.