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In this episode of US-UK Tax Talk, Aidan Grant, Partner in the Tax & Estate Planning team at Collyer Bristow, answers common listener questions on estate planning for Americans living in the UK. From wills and probate to living trusts, inheritance tax, family gifting, property ownership, and powers of attorney, Aidan explains when estate planning can stay simple, where cross-border complexity genuinely arises, and how US citizens in the UK can approach planning decisions with confidence. Come back for new episodes of US-UK Tax Talk released on the first Wednesday of every month. For questions or feedback, please contact us at [email protected] 🔗 Aidan Grant – Partner, Tax & Estate Planning https://collyerbristow.com/people-listing/aidan-grant/ 🔗 Collyer Bristow – Tax & Estate Planning Team  https://collyerbristow.com/ 🎧 Listen on the go https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 What’s Covered?  Does my estate planning have to be complex just because I’m an American living in the UK? Being subject to two tax systems does not automatically mean your estate plan needs to be complicated. Simple objectives can often be met with simple planning.I’m an American living in the UK with assets in both countries. Do I need a will in both jurisdictions? There is no fixed rule. The right approach depends on probate timing, cost, and administrative efficiency.A US attorney has recommended a living trust to avoid US probate, should I do that? US living trusts can be effective but are not always the right solution for UK-resident Americans and may create UK tax issues if used incorrectly.My estate planning wishes are simple, but I’m worried about UK inheritance tax, what can I do? Inheritance tax exposure can often be managed without over-engineering, but cross-border alignment is essential.My parents live in the US and want to make lifetime gifts to me. Are there UK tax issues? Yes. UK tax consequences can arise for UK-resident recipients even when gifts are made by US-based parents. My parents are redoing their US estate planning. Does my UK residence matter? Yes. The residence and tax position of beneficiaries can materially affect how US estate planning works in practice. My spouse and I are buying a home in the UK. I’m American, but my spouse isn’t,  should we think about ownership? Property ownership structure can have significant estate planning and tax implications for mixed-nationality couples.Should I put powers of attorney in place in both the US and the UK? Powers of attorney are jurisdiction-specific and often need to be put in place separately to be effective.I know I need advice, but who do I actually need - a lawyer, accountant, or financial adviser? Cross-border estate planning usually requires coordinated advice, and knowing who to involve is key.

In this episode of US-UK Tax Talk, host Aidan Grant is joined by James Austen, Partner, and Henry Lopes, Associate in the Tax & Estate Planning team at Collyer Bristow, for a practical and candid discussion on HMRC inquiries, tax disputes, and what taxpayers should do when things go wrong. Drawing on extensive experience in both tax advisory and litigation, James and Henry explain how HMRC inquiries arise, the different forms of non-compliance, and why cross-border taxpayers, particularly Americans living in the UK, are disproportionately exposed to investigation risk. The conversation explores how misunderstandings between the US and UK tax systems, especially around entities like LLCs and US trusts, often lead well-intentioned taxpayers into non-compliance. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Watch recent episodes on Collyer Bristow’s YouTube channel, and connect with our Tax & Estate Planning team. Key Take Aways Non-Compliance Takes Many Forms UK tax non-compliance is not limited to deliberate wrongdoing. It can include filing late, filing incorrectly, paying tax in the wrong country, or failing to disclose income due to misunderstandings between tax systems. Many US-UK issues arise despite good intentions. Cross-Border Taxpayers Face Higher Risk Americans in the UK often remain fully compliant with the IRS while unintentionally failing UK obligations. Structures like US LLCs and living trusts are common sources of inquiry because the UK frequently taxes them differently from the US. Seek Advice Immediately Once a taxpayer becomes aware of potential non-compliance, the clock starts ticking. HMRC may treat delays of as little as 3-6 months as careless conduct, increasing penalties. Prompt professional advice is critical. Going to HMRC First Matters Unprompted voluntary disclosure significantly reduces penalties. If HMRC contacts the taxpayer first, penalties can rise dramatically, in some cases up to 100% or more of the tax due. Disclosure Facilities Are Procedural, Not Lenient The Worldwide Disclosure Facility and Digital Disclosure Facility provide a method to disclose errors, but they do not offer penalty amnesties. Taxpayers typically have 90 days to prepare full disclosures, which is often much tighter than expected. Penalties Depend on Behaviour Penalties are driven by culpability: innocent error, carelessness, or deliberate conduct. Demonstrating cooperation, transparency, and prompt disclosure can substantially reduce penalty exposure. Litigation Is a Last Resort Most disputes settle through correspondence. Tribunal litigation is expensive, time-consuming, and uncertain. Even successful taxpayers usually cannot recover legal costs at First-tier Tribunal level. Record-Keeping Is Essential Taxpayers may need to defend returns going back up to 20 years in serious cases. Maintaining accurate, long-term records is crucial, even when issues arise decades later. Don’t Panic - but Don’t Ignore It Disagreements with HMRC are common in a complex tax system. With proper advice and a structured approach, even serious issues are usually manageable and less catastrophic than feared.

In this episode of US-UK Tax Talk, host Aidan Grant is joined by colleagues James Austen, Partner, and Henry Lopes, Associate in the Tax & Estate Planning team at Collyer Bristow, for a deep and detailed exploration of one of the most challenging areas of US-UK personal taxation: how the UK treats US Limited Liability Companies (LLCs) and why this continues to create double, and sometimes triple, taxation for American taxpayers living in the UK. While LLCs are a common planning tool in the United States and are generally treated as tax-transparent, the UK often takes the opposite approach, treating them as opaque corporate entities. This mismatch leads to substantial tax exposure for UK-resident members. Aidan, James, and Henry walk listeners through the legal characterisation issues, the risk of UK corporation tax, the complexities of the Anson Supreme Court case, and HMRC’s increasingly aggressive stance in the years since. Americans living in the UK face one of the most complex cross-border tax environments in the world, and when an LLC enters the picture, that complexity multiplies. Together, the team break down how differing legal systems, conflicting tax treatments, and HMRC’s updated 2023 guidance collide to create one of the most problematic issues in the US-UK tax world. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Watch recent episodes on Collyer Bristow’s YouTube channel, and connect with our Tax & Estate Planning team. Key Take Aways: Understanding the US-UK LLC Mismatch: In the US, LLCs are generally treated as tax-transparent, with profits flowing directly to their members. The UK, however, often treats LLCs as opaque corporate bodies, taxing the entity rather than the individual. This creates a fundamental mismatch, meaning income taxed once in the US may be taxed again in the UK without relief. Why Characterisation Matters: The UK must decide how to classify foreign entities that don’t have clear UK equivalents. LLCs sit at the centre of this problem. HMRC frequently argues that LLC income belongs first to the company, not the member, leading to double taxation regardless of how the US treats the same income. This characterisation question is central to every LLC case. Why Anson Doesn’t “Fix” the Problem: The 2015 Anson v HMRC Supreme Court case initially appeared to resolve the issue in favour of transparency. However, HMRC now argues that Anson was decided on narrow findings of fact and does not apply broadly. Updated 2023 guidance makes clear that HMRC considers most LLCs to be opaque, and the department is openly seeking a new “Anson 2” case to challenge taxpayers. Legal Analysis Is Essential: Successful reliance on Anson requires a two-part legal analysis: State Law Review: Does the LLC’s governing state law allocate profits directly to the members?Operating Agreement Review: Do the specific terms mimic transparency or suggest corporate-style decision-making?  Even small wording differences in an operating agreement can fundamentally change the tax outcome.Plan Before You File: Taxpayers are far better protected when they seek advice before filing their UK return. Legal opinions, proper documentation, and clear disclosure place taxpayers in the strongest possible position against HMRC challenges. Those who delay often face higher costs, greater risk, and the possibility of becoming HMRC’s next test case.

In this episode of US-UK Tax Talk, host Aidan Grant welcomes back Patrick Mulhern, Partner at Tanager Wealth Management, for a deep dive into one of the most nuanced areas of cross border financial planning, investing for children where Americans are involved. Patrick first appeared on the show four years ago, and this return conversation explores how US and UK tax systems collide when parents and grandparents try to save and invest for minors. Americans living in the UK face a uniquely complex set of rules when planning their finances and when children enter the picture, those complexities multiply. Together, Aidan and Patrick break down how citizenship based taxation, mismatched reliefs between HMRC and the IRS. Investing for children is never simple and in the US-UK cross border context, every decision can carry long term consequences. Patrick and Aidan stress that parents should plan early, seek qualified advice, and choose simplicity and flexibility over aggressive tax optimization. In the end, a well structured plan not only protects wealth but gives families the peace of mind to focus on what really matters. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Watch recent episodes on Collyer Bristow’s YouTube channel, and connect with Tanager Wealth Management. Key Take Aways US-UK Wealth Management Basics: Americans resident in the UK must navigate two tax systems simultaneously. Products that are tax advantaged in one jurisdiction, like ISAs or US mutual funds, can create taxable events in the other. Proper wealth management means identifying compliant structures that satisfy both HMRC and the IRS, not just one. Why Children Make It Harder: Introducing minors complicates ownership, control, and reporting. Even when accounts are set up for a child’s benefit, the IRS may view them as foreign trusts, demanding disclosure and potential penalties. The UK, conversely, often sees such structures as simple nominee arrangements, leading to conflicting interpretations. The Junior ISA Problem: For British families, a Junior ISA is the natural choice for tax free growth, accessible at 18. But for a US citizen child, the IRS ignores that UK tax relief and treats the underlying funds as PFICs (Passive Foreign Investment Companies), taxed at punitive rates. Worse, Junior ISAs are locked until age 18, meaning parents can’t unwind them once they realise the problem. Safer US Options: UTMAs and UGMAs: US custodial accounts like UTMAs offer a simpler, more flexible alternative. They lack the tax free benefits of ISAs but avoid the cross border penalties. However, UK practitioners must determine whether these qualify as bear trusts or more substantive trust structures, a crucial legal distinction for UK tax treatment. The 529 Plan Dilemma: The 529 education savings plan is a favourite among American families, offering tax free growth if used for qualified education costs. But in the UK, it’s often seen as a foreign trust, with unclear or adverse tax consequences. While US grandparents can use these plans for UK based grandchildren, British resident parents are generally better off avoiding new contributions. Planning Comes First: The best results come from early, coordinated advice between cross border advisors, tax specialists, and wealth managers. Families who wait until after moving to the UK  or after funding children’s accounts often find themselves facing unnecessary tax exposure and expensive clean-up.

Welcome to US–UK Tax Talk. Host Aidan Grant is joined by Richard Taylor, founder of Plan First Wealth and host of We’re the Brits in America. Richard shares his personal journey from Manchester to Dubai to the US, and his professional insights as a financial advisor working almost exclusively with British expats in America. Together, they explore what moving to the US really looks like, beyond the clichés, and how to avoid costly financial missteps. This episode takes a hard look at the financial side of that journey. Richard and Aidan discuss why pre-arrival planning is essential, how unsuspecting expats fall into traps like punitive taxation on ISAs and PFICs, and why failing to meet reporting obligations such as FBAR and FATCA can create problems that snowball over time. They explore how the American tax system, complex, unforgiving, and layered with state-level rules, catches out even seasoned professionals who assume their UK experience will translate. The conversation also dives into the longer-term questions that many expats face: Should I take a green card? Should I become a US citizen? Richard warns that these decisions, often made without full understanding, carry lifelong consequences, including ongoing citizenship-based taxation and the risk of exit taxes. Through personal stories and professional insights, he paints a vivid picture of the opportunities and landmines that define British life in America. Key Take Aways The Expat Mindset Brits who move to the US typically do so for career and financial opportunities, not lifestyle. The country’s diversity means no two moves are alike, but the unifying factor is ambition: expats arrive determined to “make it” in America. That mindset shapes the financial planning needed to maximise the opportunity. Expectations vs. Reality Settling in takes longer than expected. From housing to cultural differences, most expats underestimate the adjustment period. What begins as a planned two-year stay often stretches into decades, with major financial consequences if planning is deferred. Pre-Arrival Planning The most common pitfall is failing to prepare before arrival. ISAs, pensions, and general investment accounts often become PFICs once in the US, leading to punitive taxation and onerous reporting. Moving portfolios into PFIC-free structures before relocating can save tens of thousands. Reporting & Compliance Many new arrivals believe “no tax due” means “no reporting required.” In fact, FBAR and FATCA require disclosure of non-US assets regardless of tax owed, with penalties starting at $10,000 per year. Missed filings, SIP treatment, and trust issues are recurring traps that can leave returns open indefinitely to IRS scrutiny. Green Cards, Citizenship & Exit Tax Too many Brits drift from visa to green card to citizenship without understanding the consequences. The US is one of the only countries taxing citizens worldwide for life. Exiting later can trigger the covered expatriate regime with harsh exit taxes and even a 40% transfer tax on gifts to US family members. Careful thought is required before locking in a status that may follow you forever. New episodes release on the first Wednesday of every month. Like, follow, and subscribe so you never miss one. Watch the video version on Collyer Bristow’s YouTube channel.  To learn more, connect with Richard Taylor via PlanFirstWealth.com, LinkedIn, or his podcast We’re the Brits in America.

In this month’s episode, Aidan Grant is joined by Alicea Castellanos, Founder and CEO of Global Taxes LLC, to explore the complexities of US tax residency — including how individuals can unintentionally become tax residents and what this means for their global income, reporting obligations, and cross-border lifestyle. From citizenship and green card status to the Substantial Presence Test, Alicea explains the different ways residency can be triggered and why it is so often misunderstood. We discuss how tax residency differs from immigration status, the potential pitfalls of failing to plan ahead, and the increasing compliance burden on those living and working between the US and UK. Alicea sheds light on when US tax residency begins and ends, the nuances of first-year exemptions, and how certain visas, such as the F-1 student visa, can temporarily delay residency status. We explore the far-reaching consequences of becoming a tax resident, from worldwide income reporting and FATCA disclosures to the challenges of managing both federal and state-level residency rules. The conversation also delves into the complexities of exiting residency and the formal processes required to surrender a green card or citizenship, including the risk of triggering an exit tax. For those living between the US and UK, Alicea highlights how the tax treaty can help resolve dual residency, while emphasising the importance of early planning to avoid costly mistakes. Whether you are arriving in the US, preparing to leave, or dividing your time between jurisdictions, this episode offers clear, practical insights to help you navigate the rules and plan with confidence. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Key Takeaways Paths to Residency: US tax residency is triggered by three routes: citizenship, green card status, or the Substantial Presence Test. Citizens are always tax residents worldwide, green card holders remain residents until they formally surrender the card, and the SPT counts days across a three-year period, with 183 days as the threshold. First-Year and Visa Nuances: Arriving with no prior US days and staying under 183 generally avoids residency in the first year. Certain visas, such as the F-1 student visa, exempt days temporarily, but this protection has limits. Short trips under 10 days may also be excluded when calculating start dates. Consequences of Residency: Once resident, individuals are taxed on worldwide income from day one. Filing is mandatory even if credits or deductions reduce liability. FBAR and FATCA reporting add further compliance, and FATCA rules often complicate opening or maintaining non-US bank accounts. State-Level Complexity: Federal residency is only part of the story. States like New York and California apply aggressive residency audits, while others such as Florida and Texas impose no income tax. Demonstrating departure from a state typically requires clear proof, such as leases or employment records. Exiting Residency: Giving up residency is rarely simple. While reducing day counts may end SPT residency, surrendering a green card or citizenship involves formal processes and may trigger exit tax. Long-term green card holders are especially at risk of being treated as covered expatriates. Dual Residency and the Treaty: It is possible to be a tax resident of both the US and the UK. In these cases, the treaty offers tiebreaker rules to determine residency, but claiming them requires paperwork and is based on subjective judgments. Avoiding dual residency through advance planning is almost always preferable.

In the latest episode of US-UK Tax Talk, Aidan Grant is joined by Joshua Moss from W1M to explore the recently introduced Foreign Income and Gain (FIG) regime and the challenges faced by American expats adjusting to the UK's evolving tax landscape. Hear how FIG offers strategic opportunities for newcomers and returning residents to the UK, providing a four-year tax-free window, and the advantages of pre-arrival planning to ensure tax compliance and effective asset structuring under the FIG regime. From the reduced tax rate offered by the temporary repatriation facility (TRF) to the changing treatment of pensions under UK inheritance tax laws, we explore the critical role of wealth managers in advising clients amidst these sweeping changes. Discover the complexities of managing US investments, the implications of revised inheritance tax regulations, and how these changes affect estate planning strategies for international families residing in the UK. This episode provides valuable insights into transitioning from the remittance basis to a more advantageous temporary repatriation regime, empowering expats to bring money into the UK at a reduced tax rate. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Key Takeaways: New Tax Regimes in the UK: Significant changes to UK tax rules, effective from April 6, 2025, include two notable regimes: the "Foreign Income and Gain Regime" (FIG), offering a four-year tax-free period for individuals new to the UK or those who have lived outside the UK for at least ten tax years; and the "Temporary Repatriation Facility" (TRF), allowing individuals previously on the remittance basis to bring their foreign income into the UK at a reduced tax rate of 12%-15%, rather than the higher default rates. Impact on Cross-Border Wealth Management: These changes create new considerations for internationally mobile individuals and wealth managers. The flexibility and adaptability of financial planning now hinge on navigating these updated regulations and optimizing strategies for clients moving between jurisdictions. Inheritance Tax Implications: The revised rules clarify the exposure to UK inheritance tax. Individuals residing in the UK for 10 out of the last 20 years are subject to inheritance tax on worldwide assets. However, during the first ten years, inheritance tax liability is generally limited to UK-based assets. Strategic Financial Planning Adjustments: The FIG regime and TRF are game-changers for tax and financial planning. Clients relocating to the UK must reassess their asset management strategies within these frameworks. The TRF provides a window of opportunity for efficient repatriation of funds, which may require tactical planning to maximize benefits. Complexities for US Taxpayers in the UK: Americans paying taxes in the US may face additional challenges with the FIG regime due to its accelerated reporting requirements compared to the previous remittance basis. This adjustment necessitates careful coordination between US and UK financial and tax considerations. Chapters: 01:45 - Introduction to Tax Changes in the UK18:33 - Understanding the New FIG Regime for American Expats in the UK21:50 - Navigating the Remittance Basis and Tax Implications36:17 - Inheritance Tax Planning and Its Implications41:51 - The Implications of Pension Tax Changes

For this month’s episode, Aidan Grant is joined by Charles Avens, Head of Immigration at Collyer Bristow, for a deep dive into the vast landscape of visa options available to Americans eyeing a move across the pond, and the risks and rewards they face when navigating UK immigration law. Discover the post-Brexit nuances of British citizenship and how citizenship opens a pathway to flexible travel to and from the UK. From citizenship by descent to the implications of future Commonwealth expansions, we explore the opportunities and challenges that lie ahead. Hear about how to navigate the visa process and learn about the criteria for transitioning from visa status to permanent residency or even British citizenship.  Charles unravels the complexities of the UK visa options, and how those seeking to come to the UK are now met with fewer and fewer options if they are not married to a UK citizen or seeking to move in connection to their business or employment.  For those visiting the UK, we also explore the essentials of Electronic Travel Authorisation and how it stacks up against the US ESTA system, highlighting the limitations and potential risks of overstaying.  The comprehensive overview also extends to the EU Settlement Scheme, providing critical updates on the government's plans for EU citizens.  We've left no stone unturned in our overview of UK family and work visa requirements, but advise staying informed to ensure you have the most up to date information needed to succeed on your immigration journey. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Key Takeaways: Visas Are a Must: If you’re not a UK citizen or permanent resident, you need a visa - no exceptions, even for Europeans post-Brexit. Plenty of Visa Options: From Skilled Workers to Students to Business Expansions, there are lots of visa options. However, the process is complex and constantly changing. High net-worth individuals simply intending to relocate to the UK and live off their personal wealth will now find it very difficult to do so. Business-Related Visas: If you are moving in connection with your business or employment then there are a range of visas available, but some require careful planning in advance. Citizenship Over Visas: If you qualify for UK citizenship, then it can be a flexible and permanent solution. However, make sure to take advice on any potentially adverse UK tax consequences that can follow.  Learn what the path to citizen involves and how to move through your visa, to permanent residence status and then finally to citizenship. Don’t Lose Permanent Residence: Permanent residence lets you stay forever, but take care not to spend too much time outside the UK or else you risk losing that status.

On this month's podcast, Aidan Grant is joined by Gillian Everall, Founder & Managing Director of Everfair Tax Consulting Ltd, to discuss the complexities of US revocable living trusts, particularly for Americans with ties to the UK. Learn more about the recent changes in UK tax law, the uncertainty surrounding the treatment of living trusts, and the importance of forming a filing position.  Explore how revocable living trusts serve as indispensable estate planning tools in the US, helping to bypass probate costs and ensure swift asset distribution, especially in states like California. Cross-border estate planning can be a maze, so the need for early intervention is essential - shaping trust agreements before they're set in stone, can help avoid potential tax pitfalls.  Gillian also offers insights into alterations in UK tax laws effective from April 2025, which will impact income and capital gains tax for UK grantors. Highlighting that paying attention now could save the headache of increased global tax liabilities and the complexities of anti-avoidance rules.  From capital gains tax considerations to inheritance tax complications, Gillian sets out the potential traps including the UK's stringent anti-avoidance provisions. Advising how important it is to separate US and UK assets to avoid unnecessary tax burdens and explore alternative strategies such as transfer-on-death and jointly held accounts. The episode serves as a reminder for anyone with assets across the Atlantic to reassess their strategies for protecting their estate. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Key Takeaways: Revocable Living Trusts Simplify Estate Planning: These trusts help avoid probate, reduce costs, and streamline asset distribution, especially in the US including states like California. Proactive Planning Is Essential: Early intervention and strategizing for trust formation can prevent adverse tax consequences and ensure compliance with both US and UK regulations. Impact of UK Tax Code Changes: Recent tax law changes in the UK will affect income and capital gains tax for grantors, making it critical to prepare for increased global tax liabilities. Legal and Tax Expertise Is Crucial: Ongoing professional advice helps navigate anti-avoidance rules, preserve exemptions, and adapt to evolving international tax systems. Separation of US and UK Assets: Maintaining distinct plans for assets in each country can minimise tax burdens and simplify estate administration.

In the first of our new monthly podcasts, Aidan Grant is joined by Bari Zahn, Founding Partner of Zahn Law Global LLC, to explore the complex world of real estate ownership for high-net-worth individuals. Bari, a US attorney with deep expertise in tax and estate planning, introduces the different ways property can be structured - direct ownership, LLCs, and various trust arrangements - highlighting the benefits, potential pitfalls, and tax implications of each. She reveals why many Americans turn to strategies like LLCs and revocable living trusts, which mimic direct ownership while offering probate and tax advantages, and Aidan considers how these solutions translate under UK tax regulations. The conversation also takes a closer look at estate planning strategies designed to avoid probate and minimise tax exposure for UK citizens investing in US real estate. With insights into tools like transfer-on-death arrangements, jointly held assets, and both living and irrevocable trusts, Bari stresses the importance of tailoring solutions to account for the unique and often complex tax treatments in both the UK and US. Using a real-life-inspired example of an American investing in UK property, the episode highlights potential tax traps, liability concerns, and the impact of co-ownership between American and non-American spouses. Nuances like ownership transparency, capital gains tax relief, and the interplay between US and UK tax systems are unpacked, providing listeners with practical guidance for navigating this cross-border minefield. The discussion wraps up with a focus on evolving compliance rules, such as the Corporate Transparency Act, and the nuanced reporting responsibilities for entities like LLCs and trusts, including beneficial ownership filing requirements for trustees. Bari also dispels common misconceptions about probate and LLCs while delivering clear takeaways for both seasoned investors and those new to international real estate. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Key Takeaways: Decoding Asset Structures: Whether held personally, through a company, or in a trust, how you own real estate shapes taxes, estate plans, and legal processes. Know the impact—structure smarter. Tax Rules Aren’t One-Size-Fits-All: US and UK tax systems treat real estate differently. The US often looks through ownership structures like trusts or LLCs for taxes. Cross-border assets? Plan tax-smart. Avoid Probate Pitfalls: Own property outright? Expect probate headaches, especially for multi-jurisdictional holdings. Solutions like living trusts can dodge probate—but beware of cross-border twists. Simplicity vs. Strategy: Simple ownership (e.g., individual name) suits modest assets. But it might cost you—think probate hassles, weak asset protection, and estate planning roadblocks. No Easy Path for Cross-Border Estates: US-UK property ownership comes with legal and tax chaos. Tackle it head-on with expert advice for seamless estate plans and robust tax strategies.

Choosing the right wealth manager is about more than just numbers; it's about trust and communication. In this episode, Aidan Grant is joined by industry experts Martin Heale and Janette Saxer from Schroders Wealth Management to discuss the key factors in selecting a proactive and approachable wealth manager who can foster long-term relationships and weather the storm of challenging market conditions. This episode explores the nuances of obtaining accreditation and maintaining seamless advisory relationships across the UK and US. Learn about the importance of transparency and effective communication with advisors to ensure efficient tax planning, especially for Americans making the move to the UK, and the value of assembling a cohesive advisory team that seamlessly coordinates across jurisdictions. The role has many job titles - investment advisor, stockbroker, wealth manager, and financial planner to name a few. Discover how these professionals serve as the quarterbacks of your financial journey, orchestrating a team of specialists to ensure your diverse financial needs are met with precision and care. Martin & Janette explain the art of selecting a wealth manager - one that not only provides value for money but also prioritizes long-term relationships and trust. They advocate personal recommendations and testimonials, bolstered by podcasts and LinkedIn, to provide a "try before you buy" experience. Navigating cross-border considerations can be a daunting task. Whether you’re new to investing or navigating significant wealth transitions, this episode is packed with expert advice to guide your financial journey. Key Takeaways: Titles like wealth manager, financial planner, or investment advisor often overlap. Pick someone who takes a holistic approach and coordinates specialists where needed. Don’t just ask for performance; request **annualized returns** and compare them to relevant benchmarks. Ask about the **total expense ratio** to understand full costs. Ensure they are qualified in both U.S. and UK financial systems. Dual-country clients need tailored advice for tax efficiency and legal compliance. Advisors must handle U.S. tax laws and UK residency rules, especially for Americans abroad or UK residents investing in the U.S. Your advisor should be someone you trust for long-term wealth management. Ensure they are proactive, have a strong, accessible team, and are equipped to regularly communicate during market ups and downs. Advisors often cater to specific asset scales (e.g., $1M+ or $5-20M+). Choose one whose client base aligns with your portfolio size. Look for testimonials, proven experience, and personal recommendations to assess their reliability.

What if the rules of tax and estate planning could be rewritten to better fit non-traditional families, particularly in the LGBTQ+ community?  In this episode, Aidan Grant is joined by Ryan J. Coyle from Bilzin Sumberg to explore the unique challenges faced by LGBTQ+ individuals, especially Americans living in the UK. They highlight traditional tax laws that often prioritise married couples and explore how they impact those who don't fit this description. With the 2018 US tax reforms setting the stage, we explore the critical concept of "sunset estate planning," urging US tax residents to act before the exclusion amount reduction in 2026. Ryan brings a wealth of knowledge on international tax issues, highlighting the importance of understanding both UK and US regulations to make informed decisions and prevent last-minute planning rushes. The episode also focuses on the evolving legal landscape for same-sex couples and unravels the intricate differences in marriage and civil partnership recognitions across US states and the UK. From the complexities of forced heirship rules to the essential legal rights for unmarried couples, we explore how these elements shape the financial future of cross-border families.  Estate planning isn't just about finances; it's about ensuring that your unique family structure is protected and respected. Hear the significance of inclusive estate planning for trans individuals, the misconceptions around common law marriage, and the nuances of property rights and inheritance laws across different jurisdictions, including the need for explicit beneficiary naming in estate documents. This episode is a must-listen for anyone seeking to understand the dynamic intersection of tax, estate planning, and LGBTQ+ rights in an international context. Key Takeaways: Marriage can provide significant tax advantages for LGBTQ+ couples in the UK and US, such as the ability to file joint tax returns and benefit from the unlimited marital deduction for estate taxes. Without a will, unmarried partners risk receiving no inheritance, as intestacy rules do not recognize them. It's crucial for such partners to engage in proactive estate planning. Families with international ties should understand how different legal systems, like forced heirship rules, can affect their estate plans to ensure their wishes are upheld. Legal documentation is essential for recognizing children from LGBTQ+ families, particularly those born through surrogacy or adoption, within estate plans. Estate planning for trans individuals must account for identity documents and be updated to reflect gender identity changes, ensuring that their rights and wishes are respected.

In this episode, Aidan Grant is joined by Daniel Jaffe, Managing Partner at Jaffe & Co, to peel back the layers of the often-overlooked tax responsibilities that come with expat life.  We explore the crucial question of who actually needs to file US tax returns while living in the UK and why overlooking this duty can lead to significant consequences. From income thresholds and foreign bank account reporting to the special case of "accidental Americans," this episode provides clarity on this complex topic, and clears up common misconceptions and streamline the path to compliance. Daniel shares insights into Foreign Bank Account Report (FBAR) requirements and the intricacies of reporting foreign financial accounts, highlighting that while these reports are informational, understanding and adhering to them is crucial for avoiding complications. Highlighting the unique challenges faced by green card holders and those inheriting US retirement accounts while abroad, providing real-life examples and expert insights to guide you through the labyrinth of international tax compliance. As tax season looms, navigating the maze of deadlines and strategies can feel overwhelming, especially when juggling obligations on both sides of the Atlantic. We break down the important deadlines US taxpayers in the UK should mark on their calendars, like April 15th and December 31st, to maximize foreign tax credits and ensure timely compliance. With insights on choosing between cash and accrued basis for tax credits, this episode is packed with practical advice for US expats aiming to optimize their tax filings. Whether you're a seasoned expat or new to living abroad, this episode offers valuable guidance to ensure you're on the right side of tax law. Key Takeaways: Every US citizen (and green card holder) is a US taxpayer, regardless of where they live or the duration of their residence outside the US. This includes taxation on worldwide income. Being physically outside the US does not exempt anyone from IRS reporting obligations or compliance. Accidental Americans or those unaware of their tax obligations can use the "Streamlined Foreign Offshore Procedures" to become IRS compliant. This involves filing the last three years’ federal tax returns and the last six years’ Foreign Bank Account Reports (FBARs). This process is specifically available for non-willful noncompliance (e.g., due to inadvertence or misunderstanding). All US persons must file FBARs (Foreign Bank Account Reports) if the total value of their foreign financial accounts exceeds $10,000 at any point during the year. This requirement applies broadly to bank accounts, pensions, ISAs, savings accounts, and even accounts held in a trustee or managerial capacity. Non-compliance carries significant potential penalties. The US-UK tax treaty allows taxpayers living in the UK to claim foreign tax credits on their US tax returns for UK taxes paid. Coordinating tax payments correctly between UK HMRC and the US IRS is critical to avoid penalties and unexpected liabilities. Timing issues, such as paying UK taxes before December 31st to align with the US tax calendar, can help optimize foreign tax credit claims. Cases involving unique income sources (e.g., ISAs, UK pensions, capital gains) or situations where tax was paid to the wrong jurisdiction (e.g., US versus HMRC) require specialist advice. Professionals can assist with tailored strategies to address compliance, minimize liabilities, and navigate international tax treaties effectively.

In this episode Collyer Bristow's Aidan Grant was invited by Richard Taylor from Plan First Wealth to appear on its 'We're the Brits in America' podcast to discuss UK Domicile & Tax Changes: What you need to know about the changes to worldwide assets. We're the Brits in America Episode Description: There are tax changes coming in the UK - new rules replacing the domicile system with a tax residency-based system. This could affect your inheritance tax exposure, among others if you’ve been out of the UK for over 10 years. To find out what it all means, Richard Taylor welcomes back Aidan Grant, a partner specialising in Tax and Trust Estates Planning at the law firm Collier Bristow. Aidan advises cross-border families and expats on navigating complex taxation and estate planning issues. The new rules in the UK are certainly complex. Plus, for those moving back to the UK or coming for the first time after being abroad for over 10 years, you can leverage the FIG regime; it allows a four-year tax exemption on foreign income and gains. This can be strategically used to manage assets and liquidate investments without UK tax burdens. How do you do it? Aidan and Richard discuss. We're the Brits in America is affiliated with Plan First Wealth LLC, an SEC registered investment advisor. The views and opinions expressed in this program are those of the speakers and do not necessarily reflect the views or positions of Plan First Wealth. Information presented is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated, are not guaranteed. Be sure to first consult with a qualified financial adviser and/or tax professional before implementing any strategy discussed herein. Plan First Wealth does not provide any tax and/or legal advice and strongly recommends that listeners seek their own advice in these areas.

Aidan Grant is again joined by guest Kristen Konschnik, Partner at London based US Law firm McLemore Konschnik. In this second episode of two, they dive deeper into tax considerations and practical solutions for charities and donors operating across borders.