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US UK cross-border tax and planning lawyers

The 'special relationship' between the US and the UK does not mean it is simple to have personal and business interests in each country. Our leading team includes US lawyers working from our London office to advise those with any kind of US connection on the best arrangements.

If you are living in the UK with any kind of US connection, you are likely to have more complicated needs when it comes to your personal and business affairs, and you may not even be aware of it.

Our leading team of US-UK tax and wealth planning lawyers working from our London office provide sophisticated advice to global clients with US connections. This advice is based on real experience and we endeavor to find both practical and creative solutions for the complex multijurisdictional issues our clients face.

We help clients with exposure to more than one legal system to create and sustain the right structures to achieve their personal, family, business and philanthropic objectives.
 
The types of client the team of US-UK tax planning lawyers regularly advise include:
  • US individuals living abroad who need integrated estate plans or tax advice.
  • Non-US individuals who require assistance managing their US connections, which may include making gifts to family members, making investments, purchasing real estate or owning businesses.
  • Non-US companies who need help from tax planning lawyers in the forming or managing of US businesses or assisting their shareholders with US tax and regulatory issues.
  • Fiduciaries, such as trustees or executors, who need assistance developing and implementing plans to mitigate taxes for US beneficiaries, or arising from US investments, or who represent a decedent with connections to both the US and the UK and exposure to estate/inheritance tax in both jurisdictions. 
  • US charities and private foundations with international objectives, and non-US charities that have US connections such as donors or investments.
  • US-based individuals and companies who have personal or business assets either in the UK or elsewhere around the world.
  • US individuals around the world who need assistance from US-UK tax solicitors resolving IRS matters or participating in the IRS voluntary compliance programs.
  • US citizens and green-card holders who wish to give up their US citizenship status.
  • US individuals living in the UK who are due to benefit from structures created by their relatives in the US.

Insight

Track record

A UK client who had lived in the US for many years and amassed significant value in his US retirement funds

We undertook research and liaised with the provider and with our US based colleagues to determine the position and enable the client to formulate an informed succession plan regarding the funds in question.

European entrepreneur currently resident in the US

He had a diverse range of business interests held through a variety of trust structures established by him and his family. The client's previous adviser had retired and he asked us to conduct a review to ensure that he was compliant with his US tax reporting obligations and to advise on the evolution of his trust holding structures. This review was completed and to the client's satisfaction confirmed that he had no undiscovered liabilities. Since then we have worked with the client and his family to develop a plan for the future devolution of his wealth and the maintenance of his children.

HNW Family

We advised on family and business governance for estate planning and succession purposes. This involved preparing Wills and trusts which were compliant with Indian law and also US tax constraints (as there are US citizen beneficiaries), advising on US citizenship and expatriation, advising on corporate and real estate structuring and lifetime gifting, advising on the Family Constitution and establishing a single Family Office for the family.

International US/UK family whose wealth emanates from a renowned private equity business.

The team have undertaken structural planning projects involving the family's trust structures and for individual family members in the light of the current (and anticipated changes both in the US and UK) tax regimes of all the relevant jurisdictions, trust and investment issues arising from the impact of the Coronavirus pandemic on the full spectrum of investments owned and taking into account the upcoming age of majority of some of the US/UK beneficiaries.

Restructuring of a Cayman trust

This advice was to eliminate large amounts of historic income and gains that otherwise would be adversely taxed at nearly confiscatory rates under the US 'throwback rules' when eventually distributed to US person beneficiaries who also are UK resident, while preserving the trust's favourable classification as an 'excluded property' and 'protected' trust for UK income, gains and inheritance tax purposes.

HNW Family

We advised on family and business governance for estate planning and succession purposes. This involved preparing Wills and trusts which were compliant with Indian law and also US tax constraints (as there are US citizen beneficiaries), advising on US citizenship and expatriation, advising on corporate and real estate structuring and lifetime gifting, advising on the Family Constitution and establishing a single Family Office for the family.

A UK client who had lived in the US for many years and amassed significant value in his US retirement funds

We undertook research and liaised with the provider and with our US based colleagues to determine the position and enable the client to formulate an informed succession plan regarding the funds in question.

European entrepreneur currently resident in the US

He had a diverse range of business interests held through a variety of trust structures established by him and his family. The client's previous adviser had retired and he asked us to conduct a review to ensure that he was compliant with his US tax reporting obligations and to advise on the evolution of his trust holding structures. This review was completed and to the client's satisfaction confirmed that he had no undiscovered liabilities. Since then we have worked with the client and his family to develop a plan for the future devolution of his wealth and the maintenance of his children.

International US/UK family whose wealth emanates from a renowned private equity business.

The team have undertaken structural planning projects involving the family's trust structures and for individual family members in the light of the current (and anticipated changes both in the US and UK) tax regimes of all the relevant jurisdictions, trust and investment issues arising from the impact of the Coronavirus pandemic on the full spectrum of investments owned and taking into account the upcoming age of majority of some of the US/UK beneficiaries.

Restructuring of a Cayman trust

This advice was to eliminate large amounts of historic income and gains that otherwise would be adversely taxed at nearly confiscatory rates under the US 'throwback rules' when eventually distributed to US person beneficiaries who also are UK resident, while preserving the trust's favourable classification as an 'excluded property' and 'protected' trust for UK income, gains and inheritance tax purposes.

A UK client who had lived in the US for many years and amassed significant value in his US retirement funds

We undertook research and liaised with the provider and with our US based colleagues to determine the position and enable the client to formulate an informed succession plan regarding the funds in question.

European entrepreneur currently resident in the US

He had a diverse range of business interests held through a variety of trust structures established by him and his family. The client's previous adviser had retired and he asked us to conduct a review to ensure that he was compliant with his US tax reporting obligations and to advise on the evolution of his trust holding structures. This review was completed and to the client's satisfaction confirmed that he had no undiscovered liabilities. Since then we have worked with the client and his family to develop a plan for the future devolution of his wealth and the maintenance of his children.

HNW Family

We advised on family and business governance for estate planning and succession purposes. This involved preparing Wills and trusts which were compliant with Indian law and also US tax constraints (as there are US citizen beneficiaries), advising on US citizenship and expatriation, advising on corporate and real estate structuring and lifetime gifting, advising on the Family Constitution and establishing a single Family Office for the family.

International US/UK family whose wealth emanates from a renowned private equity business.

The team have undertaken structural planning projects involving the family's trust structures and for individual family members in the light of the current (and anticipated changes both in the US and UK) tax regimes of all the relevant jurisdictions, trust and investment issues arising from the impact of the Coronavirus pandemic on the full spectrum of investments owned and taking into account the upcoming age of majority of some of the US/UK beneficiaries.

Restructuring of a Cayman trust

This advice was to eliminate large amounts of historic income and gains that otherwise would be adversely taxed at nearly confiscatory rates under the US 'throwback rules' when eventually distributed to US person beneficiaries who also are UK resident, while preserving the trust's favourable classification as an 'excluded property' and 'protected' trust for UK income, gains and inheritance tax purposes.

Our team

Jay Krause

Jay Krause

Partner | London

Jay Krause

Partner | London

Private client and tax

Jaime McLemore

Jaime McLemore

Partner | London

Jaime McLemore

Partner | London

Private client and tax

Maya Buckland

Maya Buckland

Partner | London

Maya Buckland

Partner | London

Private client and tax

Joseph Brothers

Joseph Brothers

Partner | London

Joseph Brothers

Partner | London

Private Client

Claire Harris

Claire Harris

Partner | London

Claire Harris

Partner | London

Private client and tax

Stephen Nerland

Stephen Nerland

Consultant | London

Stephen Nerland

Consultant | London

Private client and tax

Penelope Warr

Penelope Warr

Consultant | London

Penelope Warr

Consultant | London

Private client and tax

Katy Mitchell

Katy Mitchell

Associate | London

Katy Mitchell

Associate | London

Private Client and Tax

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