US ESTATE AND GIFT TAXATION
UK Inheritance Tax or US Estate Tax?
As a US citizen you are always subject to the US Estate and Gift tax rules. If you live in another jurisdiction, such as the United Kingdom, you may also be subject to that country's rules as well. In the United Kingdom lifetime transfers as well as the assets you own at death will be subject to the UK's Inheritance Tax, at least to some extent. As with any multi-jurisdictional situation, it is possible to be subject to double tax. The domestic law of both the UK and the US give some, but not total, relief for each other's Estate/Inheritance Tax; and there is an Estate and Gift Tax Treaty between the two countries that also helps reduce double tax. But without proper planning there is always the possibility that double tax will occur. We can assist you in planning your life-time and testamentary gifting in a tax efficient manner.