US-UK Tax Talk – Details, episodes & analysis

In the latest episode of US-UK Tax Talk, Aidan Grant is joined by Joshua Moss from W1M to explore the recently introduced Foreign Income and Gain (FIG) regime and the challenges faced by American expats adjusting to the UK's evolving tax landscape.

Hear how FIG offers strategic opportunities for newcomers and returning residents to the UK, providing a four-year tax-free window, and the advantages of pre-arrival planning to ensure tax compliance and effective asset structuring under the FIG regime.

From the reduced tax rate offered by the temporary repatriation facility (TRF) to the changing treatment of pensions under UK inheritance tax laws, we explore the critical role of wealth managers in advising clients amidst these sweeping changes. Discover the complexities of managing US investments, the implications of revised inheritance tax regulations, and how these changes affect estate planning strategies for international families residing in the UK.

This episode provides valuable insights into transitioning from the remittance basis to a more advantageous temporary repatriation regime, empowering expats to bring money into the UK at a reduced tax rate.

Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow.

Key Takeaways:

New Tax Regimes in the UK: Significant changes to UK tax rules, effective from April 6, 2025, include two notable regimes: the "Foreign Income and Gain Regime" (FIG), offering a four-year tax-free period for individuals new to the UK or those who have lived outside the UK for at least ten tax years; and the "Temporary Repatriation Facility" (TRF), allowing individuals previously on the remittance basis to bring their foreign income into the UK at a reduced tax rate of 12%-15%, rather than the higher default rates.

Impact on Cross-Border Wealth Management: These changes create new considerations for internationally mobile individuals and wealth managers. The flexibility and adaptability of financial planning now hinge on navigating these updated regulations and optimizing strategies for clients moving between jurisdictions.

Inheritance Tax Implications: The revised rules clarify the exposure to UK inheritance tax. Individuals residing in the UK for 10 out of the last 20 years are subject to inheritance tax on worldwide assets. However, during the first ten years, inheritance tax liability is generally limited to UK-based assets.

Strategic Financial Planning Adjustments: The FIG regime and TRF are game-changers for tax and financial planning. Clients relocating to the UK must reassess their asset management strategies within these frameworks. The TRF provides a window of opportunity for efficient repatriation of funds, which may require tactical planning to maximize benefits.

Complexities for US Taxpayers in the UK: Americans paying taxes in the US may face additional challenges with the FIG regime due to its accelerated reporting requirements compared to the previous remittance basis. This adjustment necessitates careful coordination between US and UK financial and tax considerations.

Chapters:

• 01:45 - Introduction to Tax Changes in the UK
• 18:33 - Understanding the New FIG Regime for American Expats in the UK
• 21:50 - Navigating the Remittance Basis and Tax Implications
• 36:17 - Inheritance Tax Planning and Its Implications
• 41:51 - The Implications of Pension Tax Changes

For this month’s episode, Aidan Grant is joined by Charles Avens, Head of Immigration at Collyer Bristow, for a deep dive into the vast landscape of visa options available to Americans eyeing a move across the pond, and the risks and rewards they face when navigating UK immigration law.

Discover the post-Brexit nuances of British citizenship and how citizenship opens a pathway to flexible travel to and from the UK. From citizenship by descent to the implications of future Commonwealth expansions, we explore the opportunities and challenges that lie ahead. Hear about how to navigate the visa process and learn about the criteria for transitioning from visa status to permanent residency or even British citizenship. 

Charles unravels the complexities of the UK visa options, and how those seeking to come to the UK are now met with fewer and fewer options if they are not married to a UK citizen or seeking to move in connection to their business or employment. 

For those visiting the UK, we also explore the essentials of Electronic Travel Authorisation and how it stacks up against the US ESTA system, highlighting the limitations and potential risks of overstaying. 

The comprehensive overview also extends to the EU Settlement Scheme, providing critical updates on the government's plans for EU citizens. 

We've left no stone unturned in our overview of UK family and work visa requirements, but advise staying informed to ensure you have the most up to date information needed to succeed on your immigration journey.

Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow.

Key Takeaways:

Visas Are a Must: If you’re not a UK citizen or permanent resident, you need a visa - no exceptions, even for Europeans post-Brexit.

Plenty of Visa Options: From Skilled Workers to Students to Business Expansions, there are lots of visa options. However, the process is complex and constantly changing. High net-worth individuals simply intending to relocate to the UK and live off their personal wealth will now find it very difficult to do so.

Business-Related Visas: If you are moving in connection with your business or employment then there are a range of visas available, but some require careful planning in advance.

Citizenship Over Visas: If you qualify for UK citizenship, then it can be a flexible and permanent solution. However, make sure to take advice on any potentially adverse UK tax consequences that can follow.  Learn what the path to citizen involves and how to move through your visa, to permanent residence status and then finally to citizenship.

Don’t Lose Permanent Residence: Permanent residence lets you stay forever, but take care not to spend too much time outside the UK or else you risk losing that status.

In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso to discuss how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the third of a three-part miniseries. 

In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso to discuss how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the second of a three-part miniseries. 

In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the first of a three-part miniseries. 

Aidan Grant is joined by Partner Jamie Austen in an Autumn Budget 2024 special. In the first episode they discussed their analysis and initial thoughts on the Labour government's Autumn Budget, announced on 30 October 2024.

In this second episode of two, they examine changes to Capital Gains Tax, Inheritance Tax, and Agricultural Property Relief, along with their implications.

Aidan Grant is joined by Partner Jamie Austen in an Autumn Budget 2024 special to discuss their analysis and initial thoughts on the Labour government's Autumn Budget, announced on 30 October 2024.

In this first episode of two, they provide initial comments on the Chancellor of the Exchequer's delivery of the Budget Statement to the House of Commons and the non-dom tax reforms it introduced. In the next episode, they'll examine changes to Capital Gains Tax, Inheritance Tax, and Agricultural Property Relief, along with their implications.

Aidan Grant and Nathania Hall continue their discussion on what Americans need to know about the UK probate process. 

In this second episode, they discuss the practicalities of UK probate in an American context including: why one might need a grant, the complexity of the process, and the circumstances where individuals might not need a grant of probate.

(00:00) Introduction
(00:35) Grant of probate discussion
(01:12) Whether a grant of probate is necessary
(04:05) Living trusts
(05:45) UK intestacy rules
(08:44) Cohabiting, unmarried partners
(13:09) Testamentary documents and foreign wills

Run time: 27 minutes

Aidan Grant is joined by Senior Associate Nathania Hall to discuss what Americans with UK assets need to know about the UK probate process. In this first episode of two, they explain how UK inheritance tax applies, and what the tax filing process looks like for an estate. In the next episode, they will consider the complexities of a UK probate application for an international estate.

(00:00) Introduction
(01:29) Discussion on inheritance tax
(12:26) When inheritance tax is due
(14:07) How to file the inheritance tax return to HMRC
(15:38) How to complete the IHT 400
(16:44) Criteria for individuals filing the IHT 400
(20:23) Spousal exemptions
(21:54) Paying inheritance tax on a property

Run time: 25 minutes

Aidan Grant and Christiaan van den Hout from Vie International are back to explore the use of life insurance in a diverse investment strategy for US/UK people.

(00:00) Introduction
(00:37) Discussion on life insurance
(04:21) Cash value plans
(10:09) Offshore bonds
(13:48) Tax efficiency
(18:27) Private placements
(19:38) Different types of policies, including non-MEC PPLI
(21:37) Life insurance trust and ILIT
(24:21) Upfront vs annual life insurance payments
(26:36) Funding policies and trusts
(28:53) US estate tax allowance vs UK inheritance tax nil rate band


Run time: 30 minutes

Securities and investment advisory services offered through M Holdings Securities, Inc a registered broker/dealer and investment advisor, member in the US. Vie International is independently owned and operated.  Authorised and regulated by the Financial Conduct Authority. This material is intended for informational purposes only and should not be construed as legal or tax advice and is not intended to replace the advice of a qualified attorney, tax advisor, or plan provider.
 
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