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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 of US/UK tax advisors, including US qualified lawyers working from our London office, advises individuals and families with US connections on appropriate tax and planning arrangements.

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

How we advise clients with US-UK connections

US/UK tax advisors providing cross border tax planning and advice

Working from our London office, our team of leading US/ UK tax advisors, including US-qualified lawyers, provide sophisticated advice to global clients with US connections. This advice is based on real experience, and we seek practical and carefully considered solutions to the complex cross border tax and estate planning issues our clients face.

We help clients with exposure to more than one legal system to create and sustain appropriate structures to support their personal, family, business and philanthropic objectives.


The types of clients we regularly advise

The types of clients the team of US/UK tax planning lawyers regularly advise include:
  • US individuals living abroad who require integrated estate planning or US-UK tax advice.
  • Non-US individuals who require assistance managing their US connections, which may include making gifts to family members, investing, purchasing real estate or owning businesses.
  • Non-US companies who need help from tax planning lawyers in the formation or management of US businesses or assisting their shareholders with US tax and regulatory considerations.
  • Fiduciaries, such as trustees or executors, who need assistance developing and implementing plans to mitigate tax exposure for US beneficiaries, or arising from US investments, or who represent a decedent with connections to both the US and the UK and potential exposure to estate or inheritance tax in both jurisdictions.
  • US charities and private foundations with international objectives, and non-US charities that have US connections including donors or investments.
  • US based individuals and companies who have personal or business assets either in the UK or elsewhere internationally.
  • US individuals around the world who need assistance from US/UK tax advisors resolving IRS matters or participating in voluntary compliance programmes.
  • US citizens and green-card holders who are considering relinquishing their US citizenship status.
  • US individuals living in the UK who are due to benefit from structures established 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

Jaime McLemore

Jaime McLemore

Partner | London

Jaime McLemore

Partner | London

Private client and tax

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Claire Harris

Claire Harris

Partner | London

Claire Harris

Partner | London

Private client and tax

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Maya Buckland

Maya Buckland

Partner | London

Maya Buckland

Partner | London

Private client and tax

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Joseph Brothers

Joseph Brothers

Partner | London

Joseph Brothers

Partner | London

Private client and tax

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Jay Krause

Jay Krause

Of counsel | London

Jay Krause

Of counsel | London

Private client and tax

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Joshua MacDonald

Joshua MacDonald

Associate | London

Joshua MacDonald

Associate | London

Private client and tax

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Grace Barrett

Grace Barrett

Associate | London

Grace Barrett

Associate | London

Private Client

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Stephen Nerland

Stephen Nerland

Consultant | London

Stephen Nerland

Consultant | London

Private client and tax

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