Hero Backdrop

Integrated US–UK tax and estate planning

Get expert guidance to ensure your estate planning is in good hands.

Families and individuals with connections to both the United States and the United Kingdom face some of the most complex tax, succession and compliance challenges in private wealth. Differing concepts of residence, domicile and citizenship, combined with parallel tax systems and extensive reporting obligations, mean that planning undertaken in isolation in one jurisdiction can have unintended — and costly — consequences in the other.

Weightmans’ US–UK tax and estate planning practice provides clear, coordinated advice for internationally mobile individuals, families, trustees and fiduciaries. We help clients navigate the interaction between UK and US tax regimes, structure their affairs efficiently, and put robust succession plans in place with confidence.

Schedule a call

Recognised as leaders in our field in all major directories

Accredited by Chambers and Partners, Spear's 500 and the Legal 500

Testimonials

A joined‑up, cross‑border approach

Successful US–UK planning requires advisers who understand both systems simultaneously. Our lawyers are experienced in advising on the full range of UK private client matters while working closely with US tax advisers, attorneys and family offices to ensure solutions are practical, compliant and aligned on both sides of the Atlantic.

US UK Wills

Where an individual or family has connections with both the UK and the US, their Will and wider estate planning need to take account of two very different legal and tax systems. This may arise through citizenship or residence, the location of family members, or the ownership of assets on both sides of the Atlantic. We advise US citizens living in the UK, UK individuals with US assets or family connections, and internationally mobile families on Wills and succession planning designed to work effectively across both jurisdictions. Depending on the circumstances, this may involve a single Will covering worldwide assets or coordinated UK and US Wills, with careful consideration given to UK inheritance tax, US federal and state estate taxes, the interaction between the two regimes and the treatment of existing trusts and other estate planning structures.

Cross-border estate planning is rarely something that should be considered in isolation. We work closely with our clients' US attorneys, accountants and other professional advisers to ensure that their UK arrangements complement their wider US estate plan and do not inadvertently create adverse consequences in either jurisdiction. This can include reviewing existing US Wills and trusts from a UK perspective, putting appropriate English Wills and Lasting Powers of Attorney in place, and advising on the succession and administration of estates containing assets in both countries. The objective is straightforward: to provide joined-up advice which gives clients confidence that their arrangements will operate as intended on both sides of the Atlantic.

Who we advise

We regularly act for:

  • US citizens and green card holders living in the UK
  • UK nationals living in, or moving to, the US
  • Dual citizens and internationally mobile families
  • Non‑US individuals with US assets or beneficiaries
  • Trustees, executors and fiduciaries dealing with US–UK estates and trusts
  • Entrepreneurs, business owners and senior executives with transatlantic interests
Schedule a call

Our core services

  1. Wills and estate planning
  2. Crossborder probate
  3. Tax residency and application of the US/UK double tax treaty
  4. Analysis of US structures and investments (including living trusts and LLCs, and US investments) and analysis of UK tax implications or UK tax treatment of the structure
  5. Domicile analysis and structuring under the US/UK double tax treaty
  6. Pre-immigration tax planning

Why Weightmans

  • Depth of private wealth expertise;
  • Collaborative approach;
  • Pragmatic advice;
  • Long‑term client relationships.

Our US–UK tax and estate planning solicitors

People
Photo of Jonathan Shankland

Jonathan Shankland

Partner

About Jonathan:

Jonathan heads the International Private Wealth offering at Weightmans. Jonathan is a trust, tax and estates lawyer and deals with all aspects of personal estates, wills and tax planning for UK-based and international clients. Jonathan specialises in offering international private wealth advice.

View profile
Photo of Joshua Ryan

Joshua Ryan

Principal Associate

About Joshua:

Joshua advises individuals, families, trustees, family businesses, and onshore and offshore fiduciaries on all aspects of UK and cross-border tax and succession planning.
View profile