US/UK Private Client Tax Planning

This book provides private client tax practitioners with a clearly written and practical guide to assist them in advising high net worth individuals who have UK or US residence, assets or family members, on the effective management of their finances.

The book is split into two distinct sections, the first giving an overview of the legislation advisers are likely to need to be aware of when talking to clients who may be exposed to both UK and US taxation. The second part applies the legislation to specific planning situations. These might include estate planning advice taking account of exposure to UK IHT and US estate taxes; tax efficient charitable giving where there is dual exposure to US and UK taxation; administration of international estates that include US and UK assets; and ongoing tax advice with reference to US-UK double tax treaties.

The commentary reflects recent relevant changes to tax legislation in the United Kingdom such as to the non-resident landlord scheme rules; alterations to the NRCGT regime; and the forthcoming abolishment of the remittance basis of taxation for non-UK domiciled individuals which will impact income tax, capital gains tax and inheritance tax treatments .

In terms of US taxation the guidance will anticipate changes that might follow the introduction of the new Republican Government., as well as the expected expiration of certain provisions in 2026. Commentary is added to explain the planning opportunities for controlled foreign companies and the US estate exemption. The US federal estate exemption amount (currently $13.61 million) is due to sunset at the end of 2025 which could reduce the amount an individual can pass on tax free.