Trust & Estate Tax Services – US & UK Specialists
US UK Tax Advisors provide expert support with trust taxation, estate planning, and gift reporting for families with assets in both the US and UK. Our dual- qualified advisors handle IRS and HMRC compliance, reduce double taxation, and create strategies that protect wealth and ensure smooth succession across generations.
US–UK Trust Tax Advisors – IRS & HMRC Compliance
Managing trusts and estates across both the US and UK tax systems is highly complex. Families with international assets face strict reporting rules, estate tax exposure, and succession planning challenges that require specialist cross-border expertise.
At US UK Tax Advisors, we provide tailored guidance on trust compliance, estate planning, and gift tax reporting, ensuring assets are protected while meeting both IRS and HMRC requirements. Our approach minimises risks and helps families avoid costly mistakes.
Our dual-qualified advisors work with families, trustees, and executors to streamline cross-border reporting, reduce double taxation, and build long-term strategies for wealth preservation and succession.
We guide international families, trustees and executors through trust and estate tax across the US and UK. Our work covers foreign trust reporting, estate and inheritance tax, gift planning and cross-border succession, using the US-UK estate tax treaty to reduce double taxation and preserve wealth across generations.
Key Takeaways
- US estate tax applies to worldwide assets of citizens and domiciliaries; UK inheritance tax turns on domicile and situs
- A separate US-UK estate and gift tax treaty allocates rights and relieves double charges
- US beneficiaries and settlors of foreign trusts face Form 3520 and 3520-A reporting with heavy penalties
- US and UK gift and trust rules rarely align, so timing and structure need coordinated planning
US–UK Cross-Border Tax: Key Facts
$10,000
Aggregate in foreign accounts at any point in the year triggers a mandatory FBAR (FinCEN Form 114) for US persons.
Source: IRS — FBARWorldwide
US citizens and Green Card holders must file a US return on worldwide income every year, regardless of where they live.
Source: IRS — Citizens Abroad$120,000+
The Foreign Earned Income Exclusion lets qualifying Americans abroad exclude over $120,000 of earned income (indexed annually).
Source: IRS — FEIE31 January
UK Self Assessment online returns and any tax owed are due by 31 January following the 5 April tax year end.
Source: GOV.UK — Self AssessmentOur Expertise at a Glance
Working with general accountants is rarely enough when it comes to cross-border trusts and estates. Families choose US UK Tax Advisors because we:
- Specialise in US–UK estate and trust taxation
- Advise on inheritance, gift, and succession planning
- Offer dual-qualified expertise in both IRS and HMRC rules
- Provide tailored strategies for families with multi-jurisdiction assets
- Deliver peace of mind by simplifying complex tax challenges
We don ’t just prepare forms—we help families preserve wealth, plan succession, and stay compliant across generations.
Wealth, Succession & Trust Tax Services – US & UK Focus
Trust and estate taxation across the US and UK is complex, with strict reporting requirements under both the IRS and HMRC. We specialize in US–UK trust tax compliance, including Form 3520 and 3520-A filings, estate tax returns (Form 706), UK inheritance tax, and gift reporting.
Effective cross-border planning goes beyond compliance—it requires strategy. We design tailored succession and estate plans that protect family wealth, minimize estate and inheritance tax liabilities, and align with long-term goals.
For families with multi-jurisdiction assets, our dual-qualified experts coordinate planning across both systems. Whether you're a US citizen with UK property or a UK resident with US investments, we make sure your trusts and estates are managed seamlessly in both jurisdictions.
Trusts & Estates — US-UK Tax FAQs
How are US and UK estate taxes different?
The US levies estate tax on the worldwide assets of citizens and domiciliaries, with tax paid by the estate before distribution. The UK charges inheritance tax based on domicile and on UK situs assets. The rules, thresholds and reliefs differ significantly, so an estate connected to both countries can face charges in each. Planning is essential to avoid unnecessary double taxation.
Does the US-UK estate tax treaty prevent double taxation on death?
There is a separate US-UK estate and gift tax treaty that allocates taxing rights and provides credits so the same assets are not fully taxed by both countries. It determines which country has primary rights based on domicile and asset location. Because domicile is central and hard to change, we advise early so the treaty can be applied effectively.
What US reporting applies to foreign trusts for US beneficiaries?
US persons who create, transfer to, own or receive distributions from a foreign trust face extensive IRS reporting, typically on Forms 3520 and 3520-A. Many UK structures are treated as foreign trusts for US purposes. Penalties for late or missing filings are substantial and calculated by reference to the trust's assets or distributions, so accurate, timely reporting is critical.
How is a UK trust taxed for a US settlor or beneficiary?
A UK trust that is efficient under HMRC rules can create adverse US consequences, including current taxation of income, the throwback rules on accumulated income, and PFIC issues on underlying investments. US and UK trust taxation rarely align. We review the trust deed and asset mix to identify exposure and, where possible, restructure to reduce the combined tax burden.
Are lifetime gifts taxed differently in the US and UK?
Yes. The US has a gift tax on lifetime transfers by citizens and domiciliaries, with an annual exclusion and a unified lifetime exemption, and gifts to a non-citizen spouse are limited. The UK instead relies on potentially exempt transfers that fall outside inheritance tax if the donor survives seven years. Coordinating gifting across both systems requires careful timing and documentation.
How do you help executors and trustees with cross-border estates?
We support executors and trustees through the full cross-border process: valuing worldwide assets, determining domicile, preparing US estate and UK inheritance tax filings, claiming treaty relief and foreign tax credits, and handling ongoing trust and beneficiary reporting. Coordinating both jurisdictions in the right order helps avoid double taxation, penalties and delays in administering the estate.
Written & reviewed by the US-UK Tax Advisors cross-border tax team — chartered specialists in US and UK taxation, IRS and HMRC compliance, FATCA/FBAR reporting and double-taxation treaty planning.
Last reviewed: July 2026. This page is for general information and is not personal tax advice.
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Managing cross-border taxes doesn't have to be complicated. Whether you're a US citizen living in the UK, a UK resident with US tax obligations, or a business operating internationally, our team of specialist US UK tax accountants in London is here to help.