High Net Worth Individuals
Coordinated US and UK planning for significant wealth: the FIG regime, estate tax and IHT, cross-border trusts, and investment structuring handled as one strategy by one team.
Wealth planned in one system unravels in the other.
Significant wealth spanning the US and UK sits under two codes that disagree on trusts, gifts, funds, and death itself. A structure that's elegant in one country can be an ongoing tax event in the other. We plan the whole position (income, gains, succession, and giving) as one coordinated strategy, tested against both systems before anything is signed.
From the FIG regime's four-year window to estate treaty positions and trust restructuring, we advise families, founders, and their existing advisory teams on both sides of the Atlantic.
How we help high net worth families
Coordinated US and UK planning across income, investments, trusts, and succession.
Coordinated Wealth Planning
A single strategy across both systems: income, gains, gifts, and succession modeled together so a position that works in one country isn't undone by the other.
FIG Regime & Residence Planning
The remittance basis is gone. The four-year Foreign Income and Gains regime rewards arriving in the UK with a plan already in place. We build it before you land.
Estate Tax & IHT Coordination
US estate tax and UK inheritance tax start from different concepts (citizenship and domicile) and both can reach the same assets. We apply the estate tax treaty so exposure is measured once and planned deliberately.
Trusts Across Borders
A trust that's efficient in one system can be punitive in the other: US grantor and throwback rules on one side, the UK relevant property regime and ten-year charges on the other. We stress-test structures against both before they're funded.
PFIC-Aware Investment Structuring
At scale, non-US funds and wrappers create PFIC exposure that builds up unnoticed. We work with your investment managers to structure portfolios that stay efficient in both systems.
Charitable Giving in Both Systems
A gift deductible in only one country wastes relief. Dual-qualified charitable structures let a single donation attract US deduction and UK Gift Aid treatment. We design the giving to qualify in both.
Put your whole cross-border position under one strategy before the next structure is signed.
Get StartedExplore our tax services
Two death taxes, one estate.
US estate tax follows citizenship; UK inheritance tax now follows long-term residence. For cross-border families, both can reach the same assets, and the 1978 treaty only helps estates that were arranged with it in mind. We plan while the options are still open.
The expensive mistakes are structural.
At this level, the tax cost rarely comes from a missed deduction; it comes from a trust, fund, or residency decision made with only one system in view. We test every material structure against both codes, and sequence the moves that can't be undone.
Structure Stress-Testing
Every trust, holding company, and wrapper is reviewed against both codes (grantor rules, relevant property charges, and reporting duties) before it's created or funded.
Gift & Succession Sequencing
Lifetime gifts are taxed on different principles in each country. We sequence transfers so exemptions, potentially exempt transfers, and treaty credits all do their work.
Exit & Residency Planning
Leaving either system has a price: the US expatriation tax on one side, residence and temporary non-residence rules on the other. We model the exit before you commit to it.
Investment Mandate Alignment
Your managers' mandate should encode the tax constraints (PFIC screens, reporting fund status, situs of assets) so efficiency is built in rather than repaired later.
Why high net worth families choose US/UK Cross Border Tax
One Strategy, Two Systems
Wealth planning fails at the seams. Our US and UK advisers work the same balance sheet, so every structure is tested against both codes before it exists.
Treaty Depth
The income tax treaty and the estate and gift tax treaty are different instruments with different rules. We work both, daily and in detail.
Adviser Coordination
We work alongside your investment managers, private bankers, and lawyers in both countries, as one tax voice across the whole advisory team.
Discretion & Continuity
Significant wealth needs advisers who plan in decades rather than tax seasons. Engagements are built for long-term continuity across generations and jurisdictions.
"After the non-dom changes we needed the US and UK advice to actually connect: the family trust, the fund holdings, the estate plan, all of it. They rebuilt the position as one strategy and now sit in on calls with our lawyers and managers in both countries."
Private Wealth Tax Questions
Common questions from individuals and families with significant cross-border wealth.
Two Tax Systems, One Team
Email Us
hello@usukcrossbordertax.comLondon Headquarters
4 Crown Place
London EC2A 4BT
United Kingdom
Manchester
CORE
Brown St, Manchester M2 1DH
United Kingdom
San Francisco
600 California St
San Francisco, CA 94108
United States
New York
33 Irving Pl
New York, NY 10003
United States