Who we help
Families & trusts
Gifts, trusts and inheritances cross borders badly, and the reporting attaches to the recipient as often as the giver.
A trust that works in one country is often a reporting problem in the other.
UK family trusts are ordinary planning. To a US beneficiary they are foreign trusts, with Forms 3520 and 3520-A and penalties that do not depend on any tax being due.
Inheritances and large gifts from abroad are reportable too, even where they are entirely untaxed.
What we handle
01
Foreign trusts
Reporting for US settlors and beneficiaries of UK trusts, including the distribution rules.
02
Gifts from abroad
Large gifts or bequests from non-US persons are reportable by the US recipient above set thresholds.
03
Estate and inheritance tax
Two regimes with different thresholds and reliefs, both potentially reaching the same estate.
04
Children with US status
A US-citizen child has filing obligations of their own once they have income, including from a trust.
Why us
Penalties that ignore whether tax is due
Foreign trust reporting carries some of the harshest penalties in the US code, and they apply to late forms rather than to unpaid tax.
Most of what we do here is making sure the right forms exist at all, which is unglamorous and worth considerably more than it sounds.
Frequently asked
My parents want to put UK assets in trust for me. Does that matter?
If you are a US person, yes — considerably. It is worth advice before the trust is created, because the structure determines the reporting you will carry for its life.
I inherited money from a UK relative. Do I report it?
An inheritance from a non-US person is generally not US-taxable to you, but above certain thresholds it is reportable on Form 3520. Reportable and taxable are different questions.
What are Forms 3520 and 3520-A?
3520 reports transactions with foreign trusts and large foreign gifts; 3520-A is the annual return for a foreign trust with a US owner. Both carry substantial late-filing penalties independent of any tax.
What is the reporting threshold for a foreign gift?
For gifts or bequests from non-US individuals or estates, reporting starts above $100,000 in a year. Lower thresholds apply to gifts from foreign corporations and partnerships.
Is a UK bare trust a foreign trust?
For US purposes it may be treated as a grantor trust or disregarded, depending on its terms. The label used in the UK does not determine the US analysis.
Can I set up a trust for US-resident grandchildren?
Yes, but the structure determines the reporting they will carry for its life. It is far better designed with the US side in mind than retrofitted.
Does a UK will cover US assets?
Not always effectively. Assets in the US may need separate provision, and the two estate regimes interact in ways a single-jurisdiction will rarely addresses.
Gifts, trusts and inheritances cross borders badly, and the reporting attaches to the recipient as often as the giver.
Talk it through
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