Trusts &
Estates
Integrated US & UK Estate Planning
Families with connections to both the US and UK face unique estate planning challenges. Different inheritance tax regimes, trust rules, and reporting requirements demand specialist cross-border expertise.
We provide coordinated trust and estate planning services that protect your wealth, ensure smooth succession, and minimise tax across both jurisdictions.
Inheritance Tax
Strategic planning to minimise UK IHT and US estate tax exposure for cross-border families.
Cross-Border Trusts
Optimal trust structures that work effectively across both US and UK tax systems.
Wealth Transfer
Efficient wealth transfer strategies across generations and jurisdictions.
Trust Reporting
Full compliance with FBAR, FATCA, and UK trust registration requirements.
One Team Powering Your Trust & Estate Strategy
Our Expertise
SERVICESTrust Formation & Administration
We advise on establishing trusts in both US and UK jurisdictions, selecting the optimal structure for asset protection, succession planning, and tax efficiency across borders.
Estate & IHT Planning
Strategic planning to minimise inheritance tax and estate tax exposure, leveraging treaties and exemptions available to cross-border families and individuals.
Succession Planning
Comprehensive succession strategies for business owners and wealthy families, ensuring smooth wealth transfer while minimising tax impact across generations.
Probate & Estate Administration
Full support through probate processes in both jurisdictions, coordinating with legal teams to ensure efficient estate administration and tax compliance.
Our Process
Initial Consultation
Strategic Planning
Implementation
Ongoing Review
Regular reviews ensure your estate plan adapts to changing laws, family circumstances, and asset positions across both countries.
Specialist US–UK
Estate Planning Advisors
Families with assets or members in both the US and UK face complex estate planning challenges. Different tax regimes, trust rules, and reporting obligations require specialist cross-border expertise.
We provide coordinated estate planning services that align your US and UK positions, identify opportunities for tax savings, and ensure your wishes are implemented effectively in both jurisdictions.
Our integrated approach means your trusts, wills, and succession planning work together seamlessly, protecting your family while preserving wealth.
Coordinated Planning
Unified estate planning across both US and UK jurisdictions.
Tax Minimisation
Strategic structuring to reduce IHT and estate tax exposure.
Trust Expertise
Optimal trust structures for cross-border families.
Succession Support
Smooth wealth transfer across generations and borders.
Explore Other Divisions
High Net Worth
Expert US–UK cross-border tax guidance for HNW and UHNW individuals with global wealth.
View →Family Offices
Comprehensive cross-border wealth, trust, and estate structuring for global families.
View →Individuals & Families
Personal tax services for US-UK connected individuals and families.
View →Questions & Answers
The US-UK estate tax treaty provides mechanisms to avoid double taxation, but careful planning is needed. We coordinate your estate plan to leverage treaty benefits and exemptions in both countries.
The optimal structure depends on your residency, domicile, and asset locations. Options include US domestic trusts, UK trusts, and offshore structures. We design solutions that achieve your goals while minimising tax.
Cross-border estates often require probate proceedings in both jurisdictions. We coordinate with legal teams to ensure efficient administration and compliance with tax obligations in each country.
US persons with interests in foreign trusts face extensive reporting obligations including Forms 3520 and 3520-A. UK trusts must register with HMRC. We ensure full compliance across both systems.
Strategies include leveraging the US unlimited marital deduction, UK spouse exemption, lifetime gifting, and appropriate trust structures. We develop tailored plans based on your family situation.
Relocation between the US and UK can trigger significant tax consequences for trust beneficiaries. We advise on pre-move planning and restructuring to minimise adverse tax impacts.
Still have questions? We're here to help.
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Ready to discuss your US-UK tax situation? Contact Jungle Tax today to explore how we can help with your cross-border tax compliance and planning needs.