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U.S.-UK Tax and Estate Planning: Advanced Techniques for Estate Planners and Tax Professionals

Reconciling U.S. and UK Law on Trusts, Cross-Border Ownership of Real Property, and Wealth Transfers

Recording of a 90-minute CLE/CPE video webinar with Q&A

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Conducted on Tuesday, January 24, 2023

Recorded event now available

or call 1-800-926-7926

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.


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.



  1. U.K. estate tax considerations for UK citizens qualifying as U.S. taxpayers
  2. UK wealth transfer regime
  3. Ownership of UK real estate by non-UK citizens
  4. 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


Mardell, Lara
Lara Mardell

Legal Director
BDB Pitmans

Ms. Mardell provides English legal and UK tax advice to individuals and trustees, particularly those with international...  |  Read More

McKeever, Marilyn
Marilyn McKeever

BDB Pitmans

Ms. McKeever works principally with international individuals and families, and the trustees of their trusts, to help...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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