US UK Tax Specialists High Net Worth Elite Guide |

Introduction

If you are a high net worth (HNW) or ultra-high net worth (UHNW) individual or family with US-UK cross-border tax exposure, the specialist capability required from your US-UK tax specialists' high net worth advisory firm extends materially beyond standard cross-border tax services. HNW positions typically combine complex compensation structures including equity awards and carried interest, substantial worldwide investment portfolios, controlled foreign corporation interests, family trust positions, family investment company holdings, multiple residence positions, and dynastic wealth transfer considerations. The integrated specialist firm capability addresses each of these dimensions simultaneously across both jurisdictions. By the end of this guide, you will understand exactly what elite HNW US-UK tax specialist capability requires, the specific structural and compliance considerations for HNW cross-border positions in the 2026 environment, the case study showing the comprehensive HNW specialism in practice, the common selection mistakes HNW individuals make, and the practical engagement framework for HNW US-UK families. This guide is written for HNW and UHNW individuals and families with cross-border US-UK exposure, including senior corporate executives, private equity and hedge fund principals, entrepreneurs and business owners, family office principals, and multi-generational wealth families navigating sophisticated dual-jurisdiction planning.

What Are US and UK Tax Specialists' High Net Worth?

The US-UK tax specialists' high-net-worth specialism describes the elite, integrated dual-jurisdiction tax advisory capability that handles comprehensive cross-border positions for HNW and UHNW individuals and families with US-UK exposure. The capability operates across both the US federal tax framework administered by the Internal Revenue Service and the UK tax framework administered by HM Revenue & Customs, with specific depth in the sophisticated structures and positions typical of HNW positions.

The HNW position category typically includes worldwide net worth exceeding $5 million per individual or £4 million per individual, with the UHNW category typically applying to positions exceeding $30 million per individual or £25 million per individual. The HNW classification triggers specific tax planning considerations across both jurisdictions, including the US estate tax framework, the UK Inheritance Tax framework, the controlled foreign corporation framework, the foreign trust framework, the FA 2025 long-term residence framework, and various other sophisticated planning areas.

The integrated capability requires dual senior credentials. The US side typically requires Enrolled Agent status under IRS Circular 230 or US CPA licensure to provide direct representation before the IRS for examinations, audits, and appeals. The UK side typically requires Chartered Tax Adviser credentials through the Chartered Institute of Taxation (CIOT) or chartered accountant credentials through the Institute of Chartered Accountants in England and Wales (ICAEW). The senior partner level at integrated HNW specialist firms typically holds 20+ years of dedicated US-UK cross-border experience with documented capability across multiple HNW client engagements.

The HNW specialism scope typically extends across multiple sophisticated areas including senior corporate executive compensation structures with equity awards, restricted stock units, performance share units, deferred compensation arrangements, and executive deferral programmes, private equity and hedge fund principal positions including carried interest taxation under IRC Section 1061 and UK CGT positioning, entrepreneur and business owner positions including controlled foreign corporation analysis under IRC Section 957, GILTI under IRC Section 951A, Subpart F income under IRC Section 951, and UK Corporation Tax positioning, family office principal positions including investment management structuring, family member tax positioning, and integrated family office accounting, multi-generational wealth families including dynasty trust positions, UK family investment company structures, UK trust positions, and integrated multi-generational planning, and substantial real property positions including US property holdings, UK property holdings, FIRPTA considerations under IRC Section 897, and UK Stamp Duty Land Tax positioning. The IRS reference for HNW international taxpayers sits at https://www.irs.gov/individuals/international-taxpayers.

Why US and UK Tax Specialists' High Net Worth Matter More Than Ever in 2026

The 2026 environment elevates the strategic importance of comprehensive HNW US-UK specialist support due to several converging factors, creating material changes affecting HNW positions.

The IRC Section 2010(c) US lifetime exemption sunset on 1 January 2026 represents the single most material recent tax change affecting HNW US-UK families. The exemption reduction from $13.99 million per individual (2025) to approximately $7 million per individual (2026 onwards) eliminates approximately $6.99 million of exemption per individual or $13.98 million per married couple. The reduction makes pre-2026 gifting strategies materially valuable for HNW families with worldwide net worth above the post-sunset threshold. The IRS lifetime exemption reference sits at https://www.irs.gov/businesses/small-businesses-self-employed/whats-new-estate-and-gift-tax.

The FA 2025 long-term residence framework, effective from the first full year (6 April 2025), replaces the prior non-dom framework with a 10 to 20-year residence test for UK IHT exposure. The framework eliminates the previous remittance basis taxation for non-doms. It introduces the four-year FIG (Foreign Income and Gains) regime for new UK arrivals, as well as the Temporary Repatriation Facility (TRF) for previously unremitted foreign income. The framework materially affects HNW US-UK positions previously relying on non-dom treatment. The HMRC FA 2025 framework reference sits at https://www.gov.uk/government/publications.

The GILTI (Global Intangible Low-Taxed Income) framework under IRC Section 951A applies to US-resident HNW individuals holding 10 percent or greater interests in controlled foreign corporations. The framework treats GILTI as imputed current income subject to US tax with specific optimization opportunities through the Section 962 election (treating the GILTI as corporate income subject to corporate rates) and the Section 250 50 percent deduction. HNW US-UK individuals with UK trading business holdings or UK family investment company structures face GILTI considerations requiring specialist optimization.

The IRC Section 1061 carried-interest framework imposes a three-year holding period for long-term capital gain treatment of carried-interest distributions from private equity and hedge fund positions. The framework affects HNW US-UK individuals in alternative asset management firms, including London-based hedge fund managers, US-based private equity partners with UK fund interests, and dual-resident principals across both jurisdictions. The integrated specialist firm addresses the carried interest positioning across both the US and UK treatment.

The Making Tax Digital ITSA expansion from 6 April 2026 introduces quarterly digital reporting requirements for UK Income Tax Self Assessment for individuals with combined property and self-employment income exceeding £50,000 (reducing to £30,000 from 6 April 2027). HNW US-UK individuals with UK property portfolios or UK self-employment positions face new compliance infrastructure requirements. The HMRC Making Tax Digital reference sits at https://www.gov.uk/government/publications/making-tax-digital.

According to the Wealth-X High Net Worth Handbook 2024, the UK currently hosts approximately 24,400 UHNW individuals with worldwide net worth exceeding $30 million, and the US-UK overlapping HNW population creates substantial demand for sophisticated, integrated specialist services. The ONS statistics reference sits at https://www.ons.gov.uk.

The Core Components of US-UK Tax Specialists' High Net Worth Capability

Compensation Structure and Equity Award Coordination

The first core component of comprehensive US-UK tax specialists' high-net-worth capability covers senior corporate executive compensation structures, including equity awards and complex deferred compensation arrangements. The component operates across the dual-jurisdiction taxation framework applicable to multi-year equity award vesting and exercise positions.

The senior corporate executive compensation framework typically includes base salary, annual cash bonus, restricted stock units (RSUs), performance share units (PSUs), stock options (both incentive stock options and non-qualified stock options), restricted stock awards, executive deferred compensation under IRC Section 409A, supplemental executive retirement plans, and various long-term incentive arrangements. Each compensation category has distinct US and UK tax treatment requiring integrated specialist coordination.

The RSU and PSU taxation framework operates differently across the US and UK jurisdictions. The US framework taxes RSUs and PSUs as ordinary compensation income at vesting under IRC Section 83 unless a Section 83(b) election applies (typically not available for RSUs given the lack of substantial risk of forfeiture at grant). The UK framework typically taxes RSUs and PSUs as employment income at vesting with PAYE collection through the employer payroll. Dual-jurisdiction taxation creates timing and credit-positioning issues that require careful integration.

The stock option taxation framework similarly varies across jurisdictions. The US framework distinguishes between incentive stock options (ISOs) under IRC Section 422 and non-qualified stock options (NSOs) under IRC Section 83. ISOs typically attract AMT exposure at exercise and long-term capital gain treatment on subsequent disposal, subject to holding periods. NSOs typically attract ordinary compensation income at exercise. The UK framework typically taxes options as employment income at exercise, with Income Tax and National Insurance treatment, subject to specific Approved Schemes (CSOP, EMI, SAYE, SIP) that provide alternative tax treatment.

The dual jurisdiction taxation creates specific HNW planning opportunities, including the IRC Section 1116 Foreign Tax Credit coordination absorbing UK tax against US tax on the same income, the treaty positioning under Article 17 of the US-UK Income Tax Convention for employment income, the timing optimization across vesting and exercise events, and the residence positioning across the multi-year vesting period.

The IRC Section 409A deferred compensation framework imposes specific requirements for nonqualified deferred compensation plans, including written election requirements, distribution event restrictions, and a 20 percent additional tax penalty for noncompliance. The framework affects HNW US-UK executives with deferred compensation arrangements requiring specific coordination across both jurisdictions.

The split-year residence position for HNW executives transitioning between US and UK residence requires specific analysis. The Statutory Residence Test under FA 2013 Schedule 45 determines the UK residence position. The substantial presence test under IRC Section 7701(b) determines a taxpayer's US residence status. The treaty tiebreaker rules under Article 4 of the US-UK Income Tax Convention resolve the dual-residence issue. The integrated specialist coordination addresses the split-year positioning cleanly. The IRS executive compensation reference sits at https://www.irs.gov/businesses/corporations/executive-compensation.

Controlled Foreign Corporation and Business Interest Coordination

The second core component covers controlled foreign corporation (CFC) and business interest coordination for HNW US-UK individuals with operating business holdings or family investment company structures. The component addresses the comprehensive US and UK tax framework applicable to substantial business holdings.

The CFC framework under IRC Section 957 applies where US persons own more than 50 percent of a foreign corporation's voting power or value. The framework imposes specific reporting requirements through Form 5471 with penalty exposure under IRC Section 6038 ($10,000 per failure per year) for non-compliance. For HNW US-UK individuals with substantial UK family company interests, the CFC analysis is critical.

The GILTI framework under IRC Section 951A applies to US shareholders of CFCs, treating GILTI as imputed current income subject to US tax. The framework operates through a complex calculation that includes the qualified business asset investment (QBAI) deduction. The optimization opportunities include the Section 962 election, which allows US individual shareholders to be taxed at corporate rates with subsequent dividend treatment of actual distributions; the Section 250 50 percent deduction, which applies to corporate-treated GILTI and provides an effective 10.5 percent US tax rate; and the Foreign Tax Credit, which positions under the IRC Section 960 indirect credit framework.

The Subpart F income framework under IRC Section 951 imposes US current taxation on specific categories of CFC income, including foreign personal holding company income, foreign base company income, and various other categories. The framework operates separately from GILTI and typically affects passive income within CFC structures.

The UK Corporation Tax framework applies to UK-resident companies, including UK family investment companies. The rates include the small profits rate at 19 percent (for taxable profits up to £50,000), the main rate at 25 percent (for taxable profits exceeding £250,000), and the marginal relief framework between thresholds. The integrated specialist coordination addresses the UK Corporation Tax and US CFC positions.

The UK family investment company (FIC) structure operates as a UK Limited Company holding family investments, with senior generation typically holding initial share classes and next generation holding growth share classes. The structure provides UK Corporation Tax efficiency on investment income, compared with higher UK personal income tax rates of 40 to 45 percent for HNW individuals. The structure also provides a multi-generational wealth transfer mechanism through growth share class design.

The IRC Section 367 outbound transfer framework applies to HNW US-UK individuals who transfer assets to foreign corporations, including UK family investment companies. The framework can impose immediate US tax recognition on outbound transfers, absent specific exceptions and gain recognition agreements. The integrated specialist coordination addresses the outbound transfer positioning.

The UK substantial shareholding exemption under TCGA 1992 Schedule 7AC provides UK CGT exemption on qualifying business disposals by UK companies. The exemption can apply to UK family investment company business divisions or qualifying trading business disposals. The integrated specialist coordination captures the exemption opportunities. The HMRC company taxation reference sits at https://www.gov.uk/government/organisations/hm-revenue-customs.

Trust and Estate Planning Coordination

The third core component covers trust and estate planning coordination for HNW US-UK families. The component addresses the comprehensive multi-generational wealth transfer framework across both jurisdictions.

The US estate tax framework under IRC Section 2001 applies to US citizens and Green Card holders on worldwide assets at death. The lifetime exemption operates under IRC Section 2010(c) at $13.99 million per individual (2025), reducing to approximately $7 million per individual (2026 onwards under the sunset). The framework creates specific HNW planning opportunities through dynasty trusts, GRATs, QPRTs, and various other structures.

The UK Inheritance Tax framework under IHTA 1984 applies to UK-resident individuals on worldwide assets after the FA 2025 long-term residence framework, with a 10-year residence threshold, is met. The framework operates at 40 percent on amounts exceeding the £325,000 nil-rate band with various reliefs and exemptions, including Business Property Relief under IHTA 1984 Section 105, Agricultural Property Relief under IHTA 1984 Section 116, and the spousal exemption.

The US dynasty trust framework provides indefinite duration trust structures in US trust-friendly jurisdictions (Delaware, South Dakota, Nevada, Alaska), allowing multi-generational wealth transfer using the senior generation's lifetime exemption. The structure removes wealth from the senior generation's estate while providing tax-efficient transfer across subsequent generations.

The UK trust framework includes discretionary trusts (attracting ten-year periodic charges and exit charges at rates up to 6 percent on chargeable transfers), interest in possession trusts (holding income beneficiary rights with capital protection mechanisms), and bare trusts (providing fully transparent treatment with beneficiary direct ownership). Each trust type has distinct UK tax treatment requiring specialist analysis.

The foreign trust framework under IRC Section 6048 imposes specific US reporting requirements through Form 3520 for US persons receiving distributions from or making transfers to foreign trusts, with Form 3520-A for annual reporting by the foreign trust itself. The penalty exposure under IRC Section 6677 (the greater of $10,000 or 35 percent of property value) creates a substantial risk of non-compliance.

The IRC Section 679 foreign trust grantor rules treat US-resident grantors of foreign trusts as deemed grantors, with subsequent US tax flow-through. The rules create specific positioning complexity for UK trusts with US-resident grantor connections.

The integrated estate and trust planning typically combines pre-2026 lifetime exemption preservation through dynasty trust funding, UK family investment company structures for UK-side wealth holding, GRAT structures under IRC Section 2702 for growth above the IRS Section 7520 hurdle rate transfer, and QPRT structures for personal residence value transfer. The optimal combination depends on the specific family position and objectives. The HMRC IHT reference sits at https://www.gov.uk/inheritance-tax.

Step-by-Step: How HNW US-UK Individuals Engage Specialist Tax Firms

Engage an integrated specialist firm with dedicated HNW US-UK cross-border experience. The firm should hold dual senior credentials, including US Enrolled Agent or CPA credentials, plus UK Chartered Tax Adviser or chartered accountant credentials, with senior partner-level experience of 15 to 20 years across HNW US-UK engagements. The firm should demonstrate capability across multiple sophisticated HNW client positions.

Conduct a comprehensive personal and family position assessment. The assessment covers worldwide net worth across all asset categories, current US-UK tax positions, existing trust and entity structures, family business interests, real property holdings, investment portfolio positioning, retirement account positions, and overall family wealth strategy objectives. The IRS reference for HNW international taxpayers sits at https://www.irs.gov/individuals/international-taxpayers.

Address the pre-2026 US lifetime exemption preservation opportunity. The IRC Section 2010(c) sunset on 1 January 2026 reduces the per-individual exemption from $13.99 million to approximately $7 million. HNW US-UK individuals and families with a worldwide net worth above $7 million per individual should evaluate pre-sunset gifting strategies, including direct gifts, dynasty trust funding, GRAT structures, and QPRT structures, depending on the specific position.

Coordinate the FA 2025 long-term residence framework positioning. UK-resident HNW US-UK individuals require analysis of their 10 of 20 years residence position, FIG regime applicability for any recent UK arrivals, Temporary Repatriation Facility utilization for any previously unremitted foreign income, and overall residence strategy. The integrated specialist coordination addresses the framework positioning cleanly.

Run the controlled foreign corporation and business interest analysis. Where the HNW position includes substantial business holdings or UK family investment company structures, the analysis covers CFC determination, GILTI optimization, including Section 962 election analysis, Subpart F income identification, UK Corporation Tax positioning, and integrated US-UK business taxation coordination.

Establish ongoing integrated annual compliance. The annual compliance covers all required US filings, including Form 1040, FBAR, Form 8938, Form 8621, Form 5471, Form 3520, Form 8833, and any other required US compliance, alongside all required UK filings, including UK Self Assessment, UK Corporation Tax for UK company positions, UK trust reporting where applicable, and Making Tax Digital ITSA where applicable from April 2026.

Coordinate the integrated trust and estate planning. The planning typically combines pre-2026 lifetime exemption preservation through dynasty trust funding, UK family investment company structures, GRAT structures (where applicable), QPRT structures (where applicable), and an integrated multi-generational wealth transfer strategy across the family.

Maintain ongoing strategic planning support throughout the year. The ongoing planning addresses changes in personal circumstances, business positions, family circumstances, regulatory developments, and other factors affecting the HNW cross-border position. The proactive engagement captures opportunities and addresses risks as they emerge throughout the year.

Real-World Example — US UK Tax Specialists High Net Worth in Practice

Case Study: Henry Whitmore — HNW Private Equity Principal With Integrated Pre-2026 Planning

Henry Whitmore is a fictional but representative profile based on typical HNW US-UK engagements. He is a 54-year-old US citizen who moved to London in 2008 to take a managing partner position at a global private equity firm, progressing to senior managing director by 2018. His position by 2025 included managing director compensation including base salary £625,000, annual cash bonus £450,000 to £750,000, carried interest distributions from multiple fund vintages totalling £1.8 million annually, average over the past five years, restricted stock units in the parent firm with current vested value of £2.4 million plus unvested awards of £3.6 million, and supplemental executive deferred compensation of £1.8 million.

Henry's worldwide net worth at 2025 stood at approximately £24 million including the Mayfair primary residence valued at £8.2 million, a Connecticut country house valued at £2.4 million (Henry retained as second residence for US visits), an existing US-domiciled investment portfolio at Goldman Sachs Private Wealth £4.8 million, a UK-domiciled investment portfolio at Coutts £3.2 million, the carried interest positions across multiple fund vintages with current carrying value approximately £4.4 million, a UK SIPP at Hargreaves Lansdown with current balance £685,000, a UK workplace pension at the firm with current accrued value £285,000, and miscellaneous assets including art collection valued at £580,000.

Henry's family comprises his wife, Sarah (52, US citizen, joined Henry in London in 2008), the two adult children (Edward, 26, US-resident US citizen finance career, New York, Catherine, 24, UK-resident US-UK dual citizen law trainee, London), and ongoing UK and US family connections, including his elderly mother in Connecticut.

Henry had used Big Four US-UK coordination during his early years in London, but the prior arrangement had not addressed the comprehensive HNW position with the required sophistication. He engaged US-UK Tax in late 2024 specifically to address the pre-2026 US lifetime exemption preservation opportunity, as well as its integration with the broader HNW position.

Our comprehensive position assessment over ten weeks systematically captured the HNW position. The assessment addressed his and Sarah's combined US lifetime exemption position at 2025 of $27.98 million through their joint citizenship, enabling gift-splitting elections under IRC Section 2513. The post-2026 sunset combined exemption would reduce to approximately $14 million, representing a preservation opportunity of $13.98 million through pre-sunset gifting.

The integrated strategy is designed to provide comprehensive pre-2026 planning across multiple structural mechanisms. First, a Delaware dynasty trust funded through $11.2 million of Henry and Sarah's combined US lifetime exemption. The Delaware trust was selected for the established trust law framework with Wilmington Trust as the trust company. Second, direct gifts totaling $2.6 million to the adult children, split between Edward and Catherine, using the remaining exemption capacity. Third, an annual exclusion gifting strategy of $36,000 per married couple, covering adult children, and future grandchildren as they arrive.

The carried-interest positioning analysis addressed Henry's average annual carried-interest distributions of £ 1.8 million. The IRC Section 1061 three-year holding period requirement applied to the carried interest distributions for long-term capital gain treatment. The integrated specialist coordination confirmed that Henry's fund vintages comfortably exceeded the three-year holding period, resulting in long-term capital gain treatment at the 20 percent maximum federal rate, plus the 3.8 percent Net Investment Income Tax. The UK CGT treatment at 28 percent on carried interest under UK provisions produced the Foreign Tax Credit coordination through Form 1116, absorbing US tax against the higher UK tax. Net US tax on carried-interest distributions is approximately nil due to the Foreign Tax Credit absorption.

The FA 2025 long-term residence framework analysis confirmed Henry and Sarah had clearly exceeded the 10 of 20 years residence threshold, subjecting them to UK IHT on worldwide assets. The dynasty trust funding addressed the long-term wealth transfer position cleanly across the framework. The integrated specialist coordination established the appropriate framework positioning for the comprehensive family wealth.

Catheria is a UK-resident US citizen, requiring specific analysis. Catherine had been a UK resident throughout her adult life and faced parallel US-UK tax exposure. Her dynasty trust beneficiary positioning provided a clean, functioning multi-generational wealth transfer mechanism. Her ongoing UK income from her law trainee position was treated as standard Foreign Tax Credit under Form 1116, with UK tax absorbed against US tax.

Edward, a US resident and US citizen, required different planning. Edward was a US resident in New York with limited UK connections. His dynasty trust beneficiary positioning operated through standard US trust beneficiary mechanisms without UK-side structural complexity. His ongoing US position would receive future dynasty trust distributions for major life events, including education funding, home purchase deposit, and potential business funding.

The deferred compensation positioning addressed Henry's £1.8 million supplemental executive deferred compensation under IRC Section 409A. The integrated specialist coordination addressed distribution planning across Henry's anticipated retirement timeline, approximately age 60, including specific distribution event scheduling and coordination of the Foreign Tax Credit for the UK tax position at distribution.

The integrated annual compliance scope across the family covered three Form 1040 returns (Henry, Sarah joint return plus separate returns where applicable for Catherine and Edward), the Form 1041 for the Delaware dynasty trust, Form 5471 reporting for any UK firm interests with controlled foreign corporation positioning, Form 3520 and Form 3520-A reporting for the dynasty trust beneficiary positions affecting US beneficiaries, four UK Self Assessment returns (Henry, Sarah, Catherine plus required UK return for Edward's UK-source income if applicable), four FBARs covering family members exceeding the threshold, and various other supporting compliance work.

Total US-UK Tax fees: £125,000 first-year engagement covering the comprehensive HNW position assessment, the dynasty trust establishment coordination, the pre-2026 exemption preservation implementation, the carried interest positioning analysis, the FA 2025 framework positioning, the deferred compensation planning, and the integrated annual compliance across all family members—subsequent annual fees: £68,000 annual retainer covering ongoing integrated compliance and strategic planning support. Get in touch with our team today at or 0333-8807974.

Henry's reflection: "The pre-2026 dynasty trust funding captured material US estate tax efficiency that we would have missed through continued reliance on the prior Big Four arrangement. The integrated US-UK specialist capability addressed carried interest positioning, deferred compensation planning, FA 2025 framework positioning, and a comprehensive family wealth strategy through single-firm engagement. The retainer model provides confidence that our complex position remains optimized through ongoing regulatory change."

Common Mistakes HNW Individuals Make With US-UK Tax Specialists Selection

Engaging Big Four firms expecting elite HNW specialist capability. Big Four firms typically operate large institutional structures with HNW US-UK matters handled through cross-border tax groups rather than dedicated HNW specialist practices. The institutional structure typically delivers strong baseline compliance but lacks the sophisticated, proactive planning capability that specialist boutique HNW firms offer. The pricing differential between Big Four and specialist boutiques is typically minimal for HNW positions, making the specialist boutique selection materially better value.

Selecting US specialist firms without integrated UK capability for inherently dual-jurisdiction positions. HNW US-UK positions require integrated dual-jurisdiction capability simultaneously. US-only firms cannot adequately address UK Self Assessment, UK Corporation Tax, UK Inheritance Tax, the FA 2025 long-term residence framework, the UK trust framework, or broader UK-side compliance and planning. Engaging separate US and UK firms produces coordination gaps and missed integration opportunities.

Missing the pre-2026 US lifetime exemption preservation opportunity. The IRC Section 2010(c) sunset on 1 January 2026 reduces the per-individual exemption from $13.99 million to approximately $7 million. HNW US-UK individuals and families with a worldwide net worth above $7 million per individual lose material exemption capacity without proactive pre-sunset planning. The IRS lifetime exemption reference sits at https://www.irs.gov/businesses/small-businesses-self-employed/whats-new-estate-and-gift-tax.

Missing the FA 2025 long-term residence framework operational positioning. The framework affects all UK-resident HNW US individuals through the 10 of 20 years residence test for UK IHT exposure. Missing the framework positioning produces unexpected UK IHT exposure on worldwide assets. Specialist analysis is required for the comprehensive positioning across the framework provisions.

Missing GILTI optimization opportunities through the Section 962 election. HNW US-UK individuals with interests in interests in controcorporations (CFCs)ions (CFCs) face GILTI exposure under IRC Section 951A. The Section 962 election allows individual shareholders to be taxed at corporate rates, with subsequent dividend treatment providing significant US tax efficiency for HNW positions. Missing the election analysis produces avoidable US tax exposure.

Treating compliance as separate from strategic planning. The integrated annual compliance provides an essential foundation, but captures only baseline value without ongoing strategic planning support. The proactive engagement addresses opportunities and risks as they emerge throughout the year, including regulatory developments, changes in family circumstances, and evolving business positions. The retainer model, which provides both compliance and strategic planning, is typically the optimal HNW engagement structure.

How US-UK Tax Helps HNW Individuals With Elite Cross-Border Planning

US-UK Tax is a specialist integrated US-UK tax advisory firm led by senior practitioners holding both US Enrolled Agent status under IRS Circular 230 and UK Chartered Tax Adviser credentials through the Chartered Institute of Taxation (CIOT). The integrated credentials provide comprehensive coverage across both jurisdictions for HNW and UHNW US-UK engagements with senior partner-level experience exceeding 20 years across the HNW cross-border specialism.

Our HNW US-UK specialist service covers comprehensive engagement including the senior corporate executive compensation structure and equity award coordination, private equity and hedge fund principal positioning including carried interest taxation under IRC Section 1061, controlled foreign corporation and business interest coordination including GILTI optimisation through Section 962 election, family investment company structuring and integration, trust and estate planning coordination including pre-2026 US lifetime exemption preservation, dynasty trust positioning, GRAT and QPRT structures where applicable, the FA 2025 long-term residence framework positioning, the comprehensive integrated annual compliance covering Form 1040, FBAR, Form 8938, Form 8621, Form 5471, Form 3520, Form 8833, UK Self Assessment, UK Corporation Tax for UK company positions, UK trust reporting where applicable, and Making Tax Digital ITSA where applicable from April 2026, the weekly tax law tracking service capturing material developments across both jurisdictions, and the ongoing strategic planning support across the year.

The HNW engagement model typically operates through annual retainer arrangements covering both compliance and strategic planning support. Engagement fees scale with the complexity of the comprehensive position, with typical ranges from £24,000 to £92,000 for standard HNW positions and £125,000 to £285,000 for UHNW family relationships with sophisticated multi-generational structures. The retainer provides predictable cost coverage and unlimited access to specialists throughout the year.

Get in touch with our team today at or 0333-8807974.

Conclusion

Three takeaways. First, comprehensive US UK tax specialists high net worth capability requires integrated dual-jurisdiction senior specialist credentials combining US Enrolled Agent or CPA credentials and UK Chartered Tax Adviser or chartered accountant credentials with documented HNW cross-border experience exceeding 15 to 20 years across multiple sophisticated client engagements covering executive compensation structures, controlled foreign corporation positions, family trust and estate planning, family investment company structures, and integrated multi-generational wealth strategy. Second, the 2026 environment creates specific strategic urgency through the IRC Section 2010(c) US lifetime exemption sunset on 1 January 2026 reducing the per-individual exemption from $13.99 million to approximately $7 million making pre-sunset gifting strategies materially valuable, the FA 2025 long-term residence framework first full year affecting all UK-resident HNW US individuals through the 10 of 20 years residence test for UK IHT exposure, the GILTI framework optimisation opportunities through Section 962 election, and the IRC Section 1061 carried interest framework affecting alternative asset management principals. Third, the HNW specialist engagement model operates through annual retainer arrangements covering integrated annual compliance plus ongoing strategic planning support plus weekly tax law tracking, with typical ranges from £24,000 to £92,000 annual retainer for standard HNW positions and £125,000 to £285,000 annual retainer for UHNW family relationships, providing predictable cost coverage and unlimited specialist access through the year. Get in touch with our team today at or 0333-8807974.

FAQs

Q: What capabilities do US and UK tax specialists with high net worth need to provide elite HNW service?

The capability requires dual senior credentials, including US Enrolled Agent status under IRS Circular 230 or US CPA licensure, plus UK Chartered Tax Adviser credentials through the Chartered Institute of Taxation (CIOT) or chartered accountant credentials through the Institute of Chartered Accountants in England and Wales (ICAEW). The senior partner level typically requires 20+ years of dedicated US-UK HNW cross-border experience with documented capability across executive compensation, controlled foreign corporation positions, family trust and estate planning, and integrated multi-generational wealth strategy. The IRS reference for HNW international taxpayers sits at https://www.irs.gov/individuals/international-taxpayers.

Q: When should HNW US-UK individuals act on the pre-2026 US lifetime exemption preservation opportunity?

The IRC Section 2010(c) sunset takes effect on 1 January 2026, making pre-sunset gifting strategies materially valuable for HNW US-UK individuals with a worldwide net worth of $7 million or more per individual or $14 million or more per married couple. The integrated specialist engagement typically requires 3 to 6 months to complete the comprehensive position assessment, design the optimal preservation strategy, and implement the gifting through dynasty trust funding, direct gifts, GRAT structures, or other mechanisms. Immediate engagement provides adequate runway for pre-sunset implementation.

Q: How does the FA 2025 long-term residence framework affect HNW US-UK individuals?

The FA 2025 framework replaces the prior non-dom framework with the 10 of 20 years residence test for UK IHT exposure, effective 6 April 2025. UK-resident HNW US individuals who meet the 10-year UK residence threshold within the rolling 20-year window become subject to UK IHT on worldwide assets. The framework eliminates the previous remittance basis taxation and introduces the four-year FIG regime for new UK arrivals, plus the Temporary Repatriation Facility for previously unremitted foreign income. The HMRC FA 2025 framework reference sits at https://www.gov.uk/government/publications.

Q: What is the GILTI optimization opportunity through the Section 962 election for HNW positions?

The GILTI framework under IRC Section 951A applies to US shareholders of controlled foreign corporations, treating GILTI as imputed current income subject to US tax. The IRC Section 962 election allows US individual shareholders to be taxed at the corporate rate (21 percent) with subsequent dividend treatment rather than at individual ordinary income rates (up to 37 percent). Combined with the IRC Section 250 50 percent deduction, which produces an effective 10.5 percent US tax rate, the election provides significant US tax efficiency for HNW US-UK individuals with controlled foreign corporation interests.

Q: What does integrated HNW annual compliance for US-UK positions typically include?

The integrated annual compliance covers all required US filings including Form 1040 federal income tax return, FinCEN Form 114 Foreign Bank Account Report, Form 8938 FATCA Statement of Specified Foreign Financial Assets, Form 8621 PFIC reporting, Form 5471 controlled foreign corporation reporting, Form 3520 foreign trust reporting where applicable, Form 8833 treaty positioning where applicable, alongside all required UK filings including UK Self Assessment, UK Corporation Tax for UK company positions, UK trust reporting where applicable, and Making Tax Digital ITSA where applicable from April 2026.

Q: How much does an integrated HNW US UK tax specialist service cost?

Integrated specialist firm engagement fees scale with the complexity of the comprehensive HNW position. Typical ranges run from £24,000 to £92,000 per annum for standard HNW positions, covering integrated annual compliance, ongoing strategic planning support, and weekly tax law tracking. UHNW positions with sophisticated multi-generational structures, including dynasty trust positions, UK family investment company structures, controlled foreign corporation positions, and substantial worldwide net worth, typically run an annual retainer of £125,000 to £285,000. The retainer model provides predictable cost coverage and unlimited access to specialists throughout the year.