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.
 
Code: 6678599.3 

In this second episode, Collyer Bristow's Aidan Grant continues his conversation with Richard Taylor from Plan First Wealth on his podcast series 'We're the Brits in America' to discuss US/UK Estate Planning. 

In this episode Collyer Bristow's Aidan Grant was invited by Richard Taylor from Plan First Wealth to appear on its 'We're the Brits in America' series of podcasts to discuss US/UK Estate Planning.

On this month's podcast, Aidan Grant is joined by Gillian Everall, Founder & Managing Director of Everfair Tax Consulting Ltd, to discuss the complexities of US revocable living trusts, particularly for Americans with ties to the UK. Learn more about the recent changes in UK tax law, the uncertainty surrounding the treatment of living trusts, and the importance of forming a filing position. 

Explore how revocable living trusts serve as indispensable estate planning tools in the US, helping to bypass probate costs and ensure swift asset distribution, especially in states like California. Cross-border estate planning can be a maze, so the need for early intervention is essential - shaping trust agreements before they're set in stone, can help avoid potential tax pitfalls. 

Gillian also offers insights into alterations in UK tax laws effective from April 2025, which will impact income and capital gains tax for UK grantors. Highlighting that paying attention now could save the headache of increased global tax liabilities and the complexities of anti-avoidance rules. 

From capital gains tax considerations to inheritance tax complications, Gillian sets out the potential traps including the UK's stringent anti-avoidance provisions. Advising how important it is to separate US and UK assets to avoid unnecessary tax burdens and explore alternative strategies such as transfer-on-death and jointly held accounts. The episode serves as a reminder for anyone with assets across the Atlantic to reassess their strategies for protecting their estate.

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:

Revocable Living Trusts Simplify Estate Planning: These trusts help avoid probate, reduce costs, and streamline asset distribution, especially in the US including states like California.

Proactive Planning Is Essential: Early intervention and strategizing for trust formation can prevent adverse tax consequences and ensure compliance with both US and UK regulations.

Impact of UK Tax Code Changes: Recent tax law changes in the UK will affect income and capital gains tax for grantors, making it critical to prepare for increased global tax liabilities.

Legal and Tax Expertise Is Crucial: Ongoing professional advice helps navigate anti-avoidance rules, preserve exemptions, and adapt to evolving international tax systems.

Separation of US and UK Assets: Maintaining distinct plans for assets in each country can minimise tax burdens and simplify estate administration.

Aidan Grant speaks to Christiaan van den Hout from Vie International about the use of life insurance in US/UK planning.

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. 

Aidan Grant and Jake Kaplan of Alston & Bird return to dig down further into the US and UK taxation of trusts.

Aidan Grant is joined by Jake Kaplan of Alston & Bird to discuss the US and UK taxation of trusts.

Aidan Grant returns with Laurence Leigh of Canaccord Genuity to continue their discussion about planning for the everyday UK resident American.

Investment involves risk. The value of investments and the income from them can go down as well as up and you may not get back the amount originally invested. This is not a recommendation to invest or disinvest in any of the companies, funds or sectors mentioned. Names of companies, funds and sectors are included for illustrative purposes only. The information provided is not to be treated as specific advice. It has no regard for the specific investment objectives, financial situation or needs of any specific person or entity. CGWM and/or its affiliates may also be holding securities of the issuers it writes on.

Aidan Grant talks to Laurence Leigh of Canaccord Genuity about tax, estate planning and investment management decisions that all UK resident Americans should consider irrespective of their wealth.

Investment involves risk. The value of investments and the income from them can go down as well as up and you may not get back the amount originally invested. This is not a recommendation to invest or disinvest in any of the companies, funds or sectors mentioned. Names of companies, funds and sectors are included for illustrative purposes only. The information provided is not to be treated as specific advice. It has no regard for the specific investment objectives, financial situation or needs of any specific person or entity. CGWM and/or its affiliates may also be holding securities of the issuers it writes on.

In this festive edition, Senior Associate Aidan Grant discusses what it's like to be an American living in the UK with his own mother Leslie Grant.

Aidan Grant returns with Holly Payling, Director at Buzzacott to further explore the complex topic of domicile.

Aidan Grant is joined by Holly Payling, Director at Buzzacott to discuss the thorny issue of domicile.

Aidan Grant returns with Reshma Shah of Duane Morris to to explore the intricacies of estate planning in the US and how this can change where a UK taxpayer becomes a part of the equation.

Aidan Grant is joined by Reshma Shah of Duane Morris to discuss what US-focused estate planning looks like and how this can change where a UK taxpayer is involved.

In the first of our new monthly podcasts, Aidan Grant is joined by Bari Zahn, Founding Partner of Zahn Law Global LLC, to explore the complex world of real estate ownership for high-net-worth individuals.

Bari, a US attorney with deep expertise in tax and estate planning, introduces the different ways property can be structured - direct ownership, LLCs, and various trust arrangements - highlighting the benefits, potential pitfalls, and tax implications of each. She reveals why many Americans turn to strategies like LLCs and revocable living trusts, which mimic direct ownership while offering probate and tax advantages, and Aidan considers how these solutions translate under UK tax regulations.

The conversation also takes a closer look at estate planning strategies designed to avoid probate and minimise tax exposure for UK citizens investing in US real estate. With insights into tools like transfer-on-death arrangements, jointly held assets, and both living and irrevocable trusts, Bari stresses the importance of tailoring solutions to account for the unique and often complex tax treatments in both the UK and US.

Using a real-life-inspired example of an American investing in UK property, the episode highlights potential tax traps, liability concerns, and the impact of co-ownership between American and non-American spouses. Nuances like ownership transparency, capital gains tax relief, and the interplay between US and UK tax systems are unpacked, providing listeners with practical guidance for navigating this cross-border minefield.

The discussion wraps up with a focus on evolving compliance rules, such as the Corporate Transparency Act, and the nuanced reporting responsibilities for entities like LLCs and trusts, including beneficial ownership filing requirements for trustees. Bari also dispels common misconceptions about probate and LLCs while delivering clear takeaways for both seasoned investors and those new to international real estate.

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:

Decoding Asset Structures: Whether held personally, through a company, or in a trust, how you own real estate shapes taxes, estate plans, and legal processes. Know the impact—structure smarter.

Tax Rules Aren’t One-Size-Fits-All: US and UK tax systems treat real estate differently. The US often looks through ownership structures like trusts or LLCs for taxes. Cross-border assets? Plan tax-smart.

Avoid Probate Pitfalls: Own property outright? Expect probate headaches, especially for multi-jurisdictional holdings. Solutions like living trusts can dodge probate—but beware of cross-border twists.

Simplicity vs. Strategy: Simple ownership (e.g., individual name) suits modest assets. But it might cost you—think probate hassles, weak asset protection, and estate planning roadblocks.

No Easy Path for Cross-Border Estates: US-UK property ownership comes with legal and tax chaos. Tackle it head-on with expert advice for seamless estate plans and robust tax strategies.

Aidan Grant is interviewed by Ben Small of Ibanista to discuss pre-arrival tax planning for Americans moving to the UK. This episode was first published as part of Just Jump, a podcast series hosted by Ibanista.

Aidan Grant returns with Joe Crome from the Charities Aid Foundation to discuss charitable giving and how to ensure it remains tax-efficient for US/UK taxpayers.

Senior Associate Aidan Grant is joined by Joe Crome from the Charities Aid Foundation to discuss how to ensure charitable giving is effective and tax-efficient when individuals are both US and UK taxpayers.

Senior Associate Aidan Grant is back with Ollie Cutting of Maseco Wealth Management to continue their discussion on the financial steps that UK-bound Americans should consider before arriving in the UK.

Senior Associate Aidan Grant is joined by Ollie Cutting of Maseco Wealth Management to discuss the financial steps that UK-bound Americans should consider before arriving in the UK.

Senior Associate Aidan Grant is back with Shawntel Randi and Alexandra Crean of Nixon Peabody to continue exploring the issues that arise with accidental Americans.

Senior Associate Aidan Grant is joined by Shawntel Randi and Alexandra Crean of Nixon Peabody to discuss the tax issues arising from being an accidental American.

Senior Associate Aidan Grant is joined by Billy Matthews of Brown Advisory to continue their discussion on US/UK investment management and in particular some of the opportunities and pitfalls in investing in funds and other collective investments.

Senior Associate Aidan Grant is joined by Billy Matthews of Brown Advisory to discuss US/UK investment management and in particular some of the opportunities and pitfalls in investing in funds and other collective investments.

Senior Associate Aidan Grant and Partner Chris McLemore from McLemore Konschnik LLP return to continue their discussion on UK/US will planning.

Choosing the right wealth manager is about more than just numbers; it's about trust and communication.

In this episode, Aidan Grant is joined by industry experts Martin Heale and Janette Saxer from Schroders Wealth Management to discuss the key factors in selecting a proactive and approachable wealth manager who can foster long-term relationships and weather the storm of challenging market conditions.

This episode explores the nuances of obtaining accreditation and maintaining seamless advisory relationships across the UK and US. Learn about the importance of transparency and effective communication with advisors to ensure efficient tax planning, especially for Americans making the move to the UK, and the value of assembling a cohesive advisory team that seamlessly coordinates across jurisdictions.

The role has many job titles - investment advisor, stockbroker, wealth manager, and financial planner to name a few. Discover how these professionals serve as the quarterbacks of your financial journey, orchestrating a team of specialists to ensure your diverse financial needs are met with precision and care.

Martin & Janette explain the art of selecting a wealth manager - one that not only provides value for money but also prioritizes long-term relationships and trust. They advocate personal recommendations and testimonials, bolstered by podcasts and LinkedIn, to provide a "try before you buy" experience.

Navigating cross-border considerations can be a daunting task. Whether you’re new to investing or navigating significant wealth transitions, this episode is packed with expert advice to guide your financial journey.

Key Takeaways:

• Titles like wealth manager, financial planner, or investment advisor often overlap. Pick someone who takes a holistic approach and coordinates specialists where needed.
  
  
• Don’t just ask for performance; request **annualized returns** and compare them to relevant benchmarks. Ask about the **total expense ratio** to understand full costs. Ensure they are qualified in both U.S. and UK financial systems.
  
  
• Dual-country clients need tailored advice for tax efficiency and legal compliance. Advisors must handle U.S. tax laws and UK residency rules, especially for Americans abroad or UK residents investing in the U.S.
  
  
• Your advisor should be someone you trust for long-term wealth management. Ensure they are proactive, have a strong, accessible team, and are equipped to regularly communicate during market ups and downs.
  
  
• Advisors often cater to specific asset scales (e.g., $1M+ or $5-20M+). Choose one whose client base aligns with your portfolio size. Look for testimonials, proven experience, and personal recommendations to assess their reliability.

Senior Associate Aidan Grant is joined by Partner Chris McLemore from McLemore Konschnik LLP to discuss UK/US will planning.

Part 2 of our latest UK/USA podcast. Senior Associate Aidan Grant is joined by Partner John Bull from Blick Rothenberg to discuss Individual Retirement Accounts (IRAs)  and break them down into 3 areas.

Senior Associate Aidan Grant is joined by Partner John Bull from Blick Rothenberg to discuss Individual Retirement Accounts (IRAs)  and break them down into 3 areas.

Part 2 of our 2 part podcast. Aidan Grant is joined by Samara Dutton to discuss how and when beneficiaries bring a claim against an estate for insufficient financial provision.

25 minutes

Aidan Grant is joined by Samara Dutton to discuss how and when beneficiaries bring a claim against an estate for insufficient financial provision.

Running time: 28 minutes

In this latest episode of UK USA, Senior Associate Aidan Grant is joined by Gillian Everall, Managing Director at Everfair Tax. Together they discuss the complex topic of lifetime trusts, looking at why they are favoured by Americans, how they sit aside UK tax rules and how the two countries approach living trusts differently. 

Senior Associate Aidan Grant is joined by Partner James Cook to discuss the meaty topic of death, including the taxes that arise on death as well as the probate and estate administration processes. James and Aidan will look especially at how the UK and US approach these matters differently and what issues clients with mixed UK/US affairs should be alert to. 

In this latest episode of UK USA, Collyer Bristow Senior Associate Aidan Grant is joined by Kristopher Heck and Patrick Mulhern of Tanager Wealth Management. Together they discuss the importance of financial planning and wealth management for US citizens living in the UK. 

In this first episode of Collyer Bristow's latest podcast series, Senior Associate Aidan Grant is joined by Senior Associate Charlie Fowler. Together they discuss tax and immigration issues relevant to US citizens looking to come to the UK. 

What if the rules of tax and estate planning could be rewritten to better fit non-traditional families, particularly in the LGBTQ+ community? 

In this episode, Aidan Grant is joined by Ryan J. Coyle from Bilzin Sumberg to explore the unique challenges faced by LGBTQ+ individuals, especially Americans living in the UK. They highlight traditional tax laws that often prioritise married couples and explore how they impact those who don't fit this description.

With the 2018 US tax reforms setting the stage, we explore the critical concept of "sunset estate planning," urging US tax residents to act before the exclusion amount reduction in 2026. Ryan brings a wealth of knowledge on international tax issues, highlighting the importance of understanding both UK and US regulations to make informed decisions and prevent last-minute planning rushes.

The episode also focuses on the evolving legal landscape for same-sex couples and unravels the intricate differences in marriage and civil partnership recognitions across US states and the UK. From the complexities of forced heirship rules to the essential legal rights for unmarried couples, we explore how these elements shape the financial future of cross-border families. 

Estate planning isn't just about finances; it's about ensuring that your unique family structure is protected and respected. Hear the significance of inclusive estate planning for trans individuals, the misconceptions around common law marriage, and the nuances of property rights and inheritance laws across different jurisdictions, including the need for explicit beneficiary naming in estate documents.

This episode is a must-listen for anyone seeking to understand the dynamic intersection of tax, estate planning, and LGBTQ+ rights in an international context.

Key Takeaways:

Marriage can provide significant tax advantages for LGBTQ+ couples in the UK and US, such as the ability to file joint tax returns and benefit from the unlimited marital deduction for estate taxes.

Without a will, unmarried partners risk receiving no inheritance, as intestacy rules do not recognize them. It's crucial for such partners to engage in proactive estate planning.

Families with international ties should understand how different legal systems, like forced heirship rules, can affect their estate plans to ensure their wishes are upheld.

Legal documentation is essential for recognizing children from LGBTQ+ families, particularly those born through surrogacy or adoption, within estate plans.

Estate planning for trans individuals must account for identity documents and be updated to reflect gender identity changes, ensuring that their rights and wishes are respected.

In this episode, Aidan Grant is joined by Daniel Jaffe, Managing Partner at Jaffe & Co, to peel back the layers of the often-overlooked tax responsibilities that come with expat life. 

We explore the crucial question of who actually needs to file US tax returns while living in the UK and why overlooking this duty can lead to significant consequences. From income thresholds and foreign bank account reporting to the special case of "accidental Americans," this episode provides clarity on this complex topic, and clears up common misconceptions and streamline the path to compliance.

Daniel shares insights into Foreign Bank Account Report (FBAR) requirements and the intricacies of reporting foreign financial accounts, highlighting that while these reports are informational, understanding and adhering to them is crucial for avoiding complications. Highlighting the unique challenges faced by green card holders and those inheriting US retirement accounts while abroad, providing real-life examples and expert insights to guide you through the labyrinth of international tax compliance.

As tax season looms, navigating the maze of deadlines and strategies can feel overwhelming, especially when juggling obligations on both sides of the Atlantic. We break down the important deadlines US taxpayers in the UK should mark on their calendars, like April 15th and December 31st, to maximize foreign tax credits and ensure timely compliance. With insights on choosing between cash and accrued basis for tax credits, this episode is packed with practical advice for US expats aiming to optimize their tax filings.

Whether you're a seasoned expat or new to living abroad, this episode offers valuable guidance to ensure you're on the right side of tax law.

Key Takeaways:

• Every US citizen (and green card holder) is a US taxpayer, regardless of where they live or the duration of their residence outside the US. This includes taxation on worldwide income. Being physically outside the US does not exempt anyone from IRS reporting obligations or compliance.
  
  
• Accidental Americans or those unaware of their tax obligations can use the "Streamlined Foreign Offshore Procedures" to become IRS compliant. This involves filing the last three years’ federal tax returns and the last six years’ Foreign Bank Account Reports (FBARs). This process is specifically available for non-willful noncompliance (e.g., due to inadvertence or misunderstanding).
  
  
• All US persons must file FBARs (Foreign Bank Account Reports) if the total value of their foreign financial accounts exceeds $10,000 at any point during the year. This requirement applies broadly to bank accounts, pensions, ISAs, savings accounts, and even accounts held in a trustee or managerial capacity. Non-compliance carries significant potential penalties.
  
  
• The US-UK tax treaty allows taxpayers living in the UK to claim foreign tax credits on their US tax returns for UK taxes paid. Coordinating tax payments correctly between UK HMRC and the US IRS is critical to avoid penalties and unexpected liabilities. Timing issues, such as paying UK taxes before December 31st to align with the US tax calendar, can help optimize foreign tax credit claims.
  
  
• Cases involving unique income sources (e.g., ISAs, UK pensions, capital gains) or situations where tax was paid to the wrong jurisdiction (e.g., US versus HMRC) require specialist advice. Professionals can assist with tailored strategies to address compliance, minimize liabilities, and navigate international tax treaties effectively.

In this episode Collyer Bristow's Aidan Grant was invited by Richard Taylor from Plan First Wealth to appear on its 'We're the Brits in America' podcast to discuss UK Domicile & Tax Changes: What you need to know about the changes to worldwide assets.

We're the Brits in America Episode Description: There are tax changes coming in the UK - new rules replacing the domicile system with a tax residency-based system. This could affect your inheritance tax exposure, among others if you’ve been out of the UK for over 10 years.

To find out what it all means, Richard Taylor welcomes back Aidan Grant, a partner specialising in Tax and Trust Estates Planning at the law firm Collier Bristow. Aidan advises cross-border families and expats on navigating complex taxation and estate planning issues. The new rules in the UK are certainly complex.

Plus, for those moving back to the UK or coming for the first time after being abroad for over 10 years, you can leverage the FIG regime; it allows a four-year tax exemption on foreign income and gains. This can be strategically used to manage assets and liquidate investments without UK tax burdens. How do you do it? Aidan and Richard discuss.

We're the Brits in America is affiliated with Plan First Wealth LLC, an SEC registered investment advisor. The views and opinions expressed in this program are those of the speakers and do not necessarily reflect the views or positions of Plan First Wealth.

Information presented is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated, are not guaranteed. Be sure to first consult with a qualified financial adviser and/or tax professional before implementing any strategy discussed herein. Plan First Wealth does not provide any tax and/or legal advice and strongly recommends that listeners seek their own advice in these areas.

Aidan Grant is again joined by guest Kristen Konschnik, Partner at London based US Law firm McLemore Konschnik. In this second episode of two, they dive deeper into tax considerations and practical solutions for charities and donors operating across borders. 

Aidan Grant is joined by guest Kristin Konschnik, Partner at London based US Law firm McLemore Konschnik. In this first episode of two, they explore the intricate regulatory landscapes for charities in the US and UK. 

Stay tuned for Part 2, where we dive deeper into tax considerations and practical solutions for charities and donors operating across borders.