Estate Planning

US taxpayers are subject to US income tax on their worldwide income and gains. US taxpayers are also subject to US Estate and Gift Tax on the transfer of their assets during life or at death. Similar taxes are imposed by other countries as well. However, there are many areas where the US tax system and the various foreign tax systems are mismatched – in the timing, the amounts or what is actually defined as taxable.

Interspousal transfers, which most married couples believe should be tax-free, may in fact be subject to tax in other countries. Plus, tax planning and tax compliance issues arise with many day-to-day events like marriage, the birth of a child, divorce, death, inheritance, setting up joint accounts, buying a home, getting a mortgage, portfolio investments and setting up a business structure. This is especially true of the US tax system and is particularly relevant to today’s multinational families. Failure to address the tax issues that arise with each of these events, or failure to take the opportunity to plan, can lead to unnecessary tax and compliance issues.

For further advice on planning ahead with key life events in mind, see here.

Our Advisory Services

Our Private Client Group and Trust Division includes a focus on a broad range of personal services, directed to our individual and business clients.

• Advice on personal tax planning and consideration for closely held businesses
• Suggestions on trust characterization from a US tax perspective such as a simple, complex, or grantor trust and the benefits of a foreign trust vs. a US domestic trust
• UK Inheritance tax calculations (IHT)
• US/UK Inheritance tax planning
• Wealth transfer planning
• Accounting services for individuals acting as fiduciaries
• Advice on timing and form of distributions to beneficiaries (e.g., cash, property or loan)
• Guidance on UNI (Undistributed Net Income), DNI (Distributable Net Income), and PTI (Previously Taxed Income)
• Advice on changes in structures as and when the settlor/beneficiary dies
• Review the structure and the terms of the governing trust agreement for suitability and to determine if changes justify revisions to the trust arrangement
• Advice on the US tax characteristics of foreign trusts and the annual filing and compliance requirements of the trusts and their beneficiaries
• Assisting the trustee with its obligations under FATCA (see also FATCA)

We are members of the GGI Global network with professional tax and legal advisors in 126 countries around the world to support complex multi-jurisdictional planning.

Our Compliance Services

We can identify and prepare all the US reporting requirements needed for estates with US Connections.

Planning ahead is important, and we are here to help

We can assist with a complete review of a taxpayer’s income and estate plan and assist in the development of a lifetime gifting program, or appropriate estate structure to minimize the overall impact of the US Estate and Gift Tax system. We also can prepare Gift Tax returns and Estate Tax returns for both citizens and non-US residents.  Contact us to discuss how we can help you