About the Course
Introduction
This CLE/CPE webinar will provide estate planners and tax professionals with a guide to estate planning tax challenges and opportunities for clients who have a tax presence in both the U.S. and UK. The panel will discuss the U.K. tax law and treaty provisions that govern tax liabilities in cross-border scenarios involving the UK and the U.S. The webinar will focus on the U.K. tax and other consequences for UK clients with a U.S. tax presence and U.S. taxpayers who own or plan to invest in UK-situs real estate and other assets.
Description
The long-standing ties between the U.S. and UK result in significant economic migration. Many U.S. citizens and permanent residents have property interests in the UK and vice versa. Estate planning counsel and advisers must identify the tax and wealth transfer planning rules and opportunities specific to U.S. and UK citizens with assets and presence in both countries.
The differences between U.S. and UK estate and wealth transfer rules present several challenges. The UK has an inheritance tax for all capital assets on the death of a taxpayer when applicable, and separate tax charges can arise on transfers to trusts and within the trusts themselves.
While the U.S.-UK tax treaty allows for reciprocal credits for U.S. estate tax and UK taxes, estate planners must reconcile the differences between the two countries' tax regimes and proactively minimize the tax impact of wealth transfers. Tax advisers must thoroughly grasp treaty provisions, identify whether a client needs separate estate documents specific to each country, and recognize the U.S. and foreign income and estate/gift tax implications of transactions.
Listen as our expert panel provides guidance on how to plan the estates of clients with both U.S. and UK tax presence, including interests in business entities, real estate, and financial accounts. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset.
Presented By
Ms. Mardell provides English legal and UK tax advice to individuals and trustees, particularly those with international connections, including the US, Canada, the Far East, the Middle East and Europe. She frequently works with local professionals from these jurisdictions, coordinating cross-border advice.
Mr. Tennant has spent his professional career focusing on trust and estate taxation for the international market in and out of London. Being dual qualified in the US and UK as well as an affiliate STEP member, he is uniquely placed to deal with complex fact patterns. Mr. Tennant has a heavy focus on clients with a connection to the US and is well known for advising US and international families on their succession strategy whilst also assisting with all the family's reporting obligations across both jurisdictions. He leads the trust and estate offering at OSCO and has spent his career building strong relationships with similarly focused advisors and trustees. Mr. Tennant's experience and network allow him to confront and resolve the unique cases posed by clients with international complexities.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Tuesday, March 3, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. U.K. estate tax considerations for UK citizens qualifying as U.S. taxpayers
II. UK wealth transfer regime
III. Ownership of UK real estate by non-UK citizens
IV. Coordinating a UK will with U.S. will and trust documents
The panel will review these and other relevant topics:
- What considerations impact U.S. taxpayers wishing to hold real estate in the UK?
- Coordinating U.S. estate plan with UK wills
- How to deal with trusts
- Treatment of inheritance of UK-situs property
