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Trusts & estates
Cross-border inheritance, gifts and trusts: two systems that diverge more here than anywhere else in the code.
Read by two very different systems.
Nothing diverges across the Atlantic like inheritance. The US taxes estates above a high threshold; the UK taxes above a low one.
A structure that is ordinary planning in one country can be a reporting problem in the other.
What we do
01
Foreign trust reporting
Forms 3520 and 3520-A for trusts and substantial gifts, where the penalties for silence are severe.
02
Estate planning
Wills and structures that work under both regimes rather than optimising for one.
03
Domicile
UK domicile and deemed domicile analysis, which drives inheritance tax exposure more than residence does.
04
Gifts and inheritances received
What has to be reported when money arrives from abroad, even where no tax is due.
Why us
Reporting, even with no tax due
Many cross-border trust and gift penalties arise on filings where nothing was owed. The obligation is informational, and the penalty is not.
We map the reporting first, then the planning.
When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.
View our peopleFrequently asked
I received an inheritance from abroad. Do I report it?
Often yes, on Form 3520, once it passes the threshold — even though a foreign inheritance is generally not US taxable income.
Does a UK trust cause US problems?
Frequently. Foreign trust rules are among the least forgiving in the code, and the reporting applies to beneficiaries as well as settlors.
Is a UK trust automatically a foreign trust?
For US purposes it is foreign unless it satisfies both the court and control tests. Most ordinary UK family trusts do not.
What are the penalties for late trust forms?
Among the harshest in the US code, and calculated by reference to the trust's assets or distributions rather than to any tax due.
How do the two estate regimes interact?
Different thresholds, different bases and different reliefs, with a separate estate and gift tax treaty. Both can reach the same asset.
Should I be a trustee of a foreign trust as a US person?
It can change the trust's classification and create reporting for the trust itself. Worth advice before accepting the appointment.
Cross-border inheritance, gifts and trusts: two systems that diverge more here than anywhere else in the code.
Key contact
Tell us what you are trying to solve and we will put the right specialist on the call.
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