UK/US Private Client
Advisory
Advisory Services
We provide tailored advisory services for private clients, trusts, and estates, specialising in the interaction of UK and US tax regimes. Our advice is always proactive, clear, and gives our informed view.
Our Advisory Services
Explore our range of UK/US tax services below or, if you are interested in talking to us about your tax situation – get in touch via our contact form.
UK Income Tax
We advise on UK income tax obligations, identifying tax-efficient approaches to income management, optimal business structure, timing of income events, understanding tax on share schemes, options, and stock awards, carried interest, and specialise in the associated concerns from cross border issues, treaties and avoiding double taxation.
State Income Tax
We advise individuals residing in or moving between states, consider the implications of multi-state taxation and state income tax implications on transactions. We assist with aligning state and federal tax filings, alongside UK tax where applicable, and claims for any unilateral foreign tax credit relief.
Capital Gains Tax Planning
Capital gains tax implications commonly arise on the sale or transfer of assets including real estate, securities, or other investments. Our dual UK and US qualified advisers can review transactions and advise on the UK, US federal and state tax implications, with the goal to achieve the best tax outcome, utilise all exemptions, deferrals, or allowances, treaty reliefs and avoid double taxation.
Advising Non-UK and Non-US Residents
Non-UK residents are generally chargeable to tax only on UK situs assets and UK source income and non-US residents only chargeable on US situs assets and US source income. We can advise on investments as a non-resident in the UK and US, spending time working in each jurisdiction as a non-resident and advice on how to remain a non-resident.
Formerly Non-UK Domiciled Clients and Remittance Basis
While the previous “non-dom” regime, allowing certain non-UK domiciled taxpayers to exclude overseas income and gains, was abolished from 6 April 2025. The rules on remittances of pre-6 April 2025 income and gains continue to apply. We can advise those who have paid the remittance basis in the past on their present tax exposure under the new regime, avoiding remittance and planning opportunities.
Coming to, and Leaving, the UK (Pre-Arrival / Pre-Departure Planning)
Planning is crucial for individuals moving to or leaving the UK, as it can profoundly impact their tax liabilities now and in the future. There are multiple aspects to ensuring tax efficiency post move, the new “FIG regime” providing relief on foreign income and gains for the first four years, managing trusts pre-arrival, understanding assets/investments that are high taxed or double taxed and much more.
For those leaving the UK, we focus on exit plans that minimize tax exposure on income and gains accrued both before and after departure.
Moving to the US (Pre-Arrival Planning)
Transitioning to the US presents a unique set of tax planning opportunities, challenges and pitfalls. Our advice includes addressing global income reporting requirements, estate tax implications, and the treatment of foreign accounts, businesses, investments and trusts under US tax laws. We advise clients on strategies to mitigate exposure to double taxation, including leveraging benefits under the UK/US tax treaty, uplifting basis of assets, and explaining the reporting regime and filing dates.
UK Statutory Residence Test Advice
The UK Statutory Residence Test (SRT) is used to decide if someone is a resident for tax purposes. Our experts help clients figure out their residency status by applying the complex SRT rules, including automatic residency and sufficient ties tests. It’s important to know your residency status to manage tax obligations, pay the right amount of tax and to the right country. Often times we advise on breaking UK residence when leaving the UK or avoiding inadvertently becoming UK resident.
US Substantial Presence (Residence) Test Advice
The US determines US tax residency (for non-citizens and green card holders), based on the number of days an individual is present in the US. Conceptually the test is simple and with proper planning, we help individuals manage their US residency status efficiently and avoid unintended tax consequences.
For those who trip the test, we look for relief from the closer connection exemption and treaty tie-breaker benefits. Otherwise, we provide insights into comprehensive global income reporting and compliance strategies as a resident.
Taxation of Passive Foreign Investment Companies (PFICs)
A PFIC is generally a foreign (non-US) company that has substantially passive income or majority passive assets on its balance sheet. Most commonly these might be non-US collective investments, but they may be private companies too. Our team specializes in helping clients identify any PFIC holdings and advising on the implications of the punitive excess distribution rules and the mitigation through mark-to-market elections, and Qualified Electing Fund elections.
We provide comprehensive strategies to help clients achieve compliance and minimize the financial impact associated with PFIC investments while ensuring proper documentation and filing of annual Form 8621.
Controlled Foreign Corporations and Form 5471
US taxpayers with a greater than ten percent interest in a Controlled Foreign Corporation (CFC) are subject to detailed reporting requirements (Form 5471) and potential anti-deferral provisions (Sub-part F and GILTI). Identifying whether you are a direct or indirect shareholder in a CFC is a challenge in itself, and we can review corporate structures, consider constructive attribution from family members and the downward attribution rules to determine when the CFC rules and reporting apply. We then advise on implications and management of issues.
Advice on Sub-part F Income and Global Intangible Low-Taxed Income (GILTI) Regimes
The sub-part F income and GILTI regimes are anti-deferral provisions that attribute income of a controlled foreign corporation directly to its US shareholders. This can have a significant impact on a personal US tax return, result in higher taxes and due to the disconnect in tax point, double taxation. Our specialists offer guidance on reducing or deferring tax impacts arising from these provisions by utilizing techniques such as foreign tax credit optimization, special elections or exemptions or entity restructuring.
UK Taxation of Carried Interest Income and Private Equity Executives
Carried interest taxation for private equity executives involves specialised rules that have changed substantially in July 2015 and periodically since. We advise on the treatment of qualifying co-invest and carried interest gains and identifying potential Disguised Investment Management Fee (DIMF) and Income Based Carried Interest (IBCI) as well as appropriate elections at grant. For those who are UK and US taxpayers our dual qualified team can help understand the interaction of the two taxes, the pain points and foreign tax credits. We can provide guidance on the new regime for carry within UK income tax from 6 April 2026.
Reporting US Partnerships on UK Tax Returns (and Interaction with Self-Assessment Rules)
Is there a challenge to meld the US calendar year tax year information with the UK fiscal year – for the most part no, there is sufficient information. However, US partnerships do create a challenge in terms of reporting and taxation, invariably with a “Schedule K-1”. We assist clients in understanding their obligations under UK self-assessment rules, specifically foreign income reporting requirements and the treatment of partnership income/gains on their tax returns.
Expatriation (Abandoning US citizenship) advice and planning
Many US citizens consider abandoning their citizenship to simplify their life or to reduce their professional costs and tax liabilities. However, there is a potential “Exit Tax”. Our advisory service provides guidance on, and an estimate calculation of, your “Exit Tax” in advance. We provide guidance on mitigation where it applies and we help you navigate the process of completing your final tax filings and expatriation return after giving up your US citizenship.
Long term residency and abandonment of green card – tax and planning
Individuals who have held a green card sufficiently long, to be “long term residents”, are potentially subject to an “exit tax”, when they abandon their green card – an action common practice if you leave the US – but also in certain other circumstances. This exit tax is often a surprise when it applies. Our advisory service provides guidance on what events may constitute abandonment of the green card and an estimate calculation of, your “Exit Tax” in advance.
Advice on application of the UK/US Treaty
The UK/US Tax Treaty plays a vital role in reducing the risk of double taxation for individuals and businesses operating across both jurisdictions. This is especially so, since US citizens are taxed by virtue of citizenship and are chargeable to US tax even though they live in the UK. The treaty provides relief from double taxation for US citizens in the form of tax credits or exemptions on income that is taxable in both the UK and the US. For certain dual resident individuals, carefully analysing the “tie-breaker” rules is necessary to establish where you are considered a tax resident, with potentially significant tax consequences. As dual handlers of UK and US tax we have deep knowledge of the treaty and its application.
Advice on making entity classification elections (check-the-box) with IRS
We provide advice on making an appropriate entity classification, often referred to as the “check-the-box” election, which is a strategic decision that can significantly influence your tax obligations and liabilities. The IRS allows eligible entities to elect to change their default classification to that of a corporation, partnership, or disregarded entity for tax purposes. Understanding the implications of each classification is essential, as it directly affects federal income tax treatment, reporting requirements, and the interaction with foreign tax credits.
Advice on foreign tax credits and avoiding double taxation
Avoiding double taxation is generally contingent on foreign tax credits and/or the provisions of the US/UK tax treaty, which is specifically designed to allocate taxing rights between the two countries. The treaty includes clauses that determine which jurisdiction has the primary right to tax certain types of income, such as dividends, interest, royalties, and pensions and also tries to deal with certain hybrid entities/trusts (with limited success).
However, utilizing foreign tax credits and incorporating treaty benefits can be intricate, present timing issues and be restricted by the US internal revenue code. This includes completing necessary forms like IRS Form 1116 or Form 8833 to disclose treaty-based positions but also paying the foreign tax at the right time and in the right amount.
Guidance on UK taxation of US LLCs and S-corps
The taxation of US LLCs and S-corporations is a contentious and challenging area of UK tax, due to differences in how these entities are treated by HMRC and the IRS. A US LLC, which is typically treated as a pass-through entity for US tax purposes, and an S-Corp whose owners pay tax on the profits through their individual tax return, are generally treated as a company by HMRC. This creates a disconnect in the character of income received, whether the “same profits” are being taxed, issues of foreign tax credit and potential double tax. We are experienced in guidance on these issues and establishing best practice reporting in returns and considering planning and mitigation.
