JUNGLE TAX
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Private Wealth & Personal Tax

Private Client Tax Services for US & UK Individuals

Coordinated cross-border tax for individuals and families with lives on both sides of the Atlantic, from personal returns and wealth structuring to trusts, domicile, and estate tax.

What is private client tax?

Private client tax services give individuals and families with US and UK interests one team for personal tax returns, wealth structuring, trusts, residency and domicile planning, inheritance and estate tax, and remittance planning. We reconcile IRS and HMRC obligations so your affairs stay compliant, efficient, and ready for the next generation.

What does a private client tax adviser handle?

Personal Returns

Dual US & UK filings

Preparation of IRS Form 1040 and UK Self Assessment, FBAR and FATCA reporting, and foreign tax credit claims so nothing falls between the two systems.

Wealth Structuring

Tax-efficient investing

Structuring portfolios, property, and business interests to manage income tax, capital gains, and reporting across both jurisdictions and avoid punitive PFIC treatment.

Trusts

Cross-border trust planning

Advice on establishing and administering trusts, aligning US grantor and foreign trust rules with UK settlements legislation for succession and protection.

Residency & Domicile

Status planning

Assessing UK residence under the Statutory Residence Test, US substantial presence, and the post-2025 UK foreign income and gains regime for new arrivals.

Estate & IHT

Inheritance & estate tax

Coordinating UK inheritance tax and US estate tax with lifetime gifting, reliefs, and treaty provisions so wealth transfers efficiently to your heirs.

Remittance

Remittance & FIG planning

Guidance for internationally mobile clients on bringing foreign income and gains into the UK cleanly under the current rules and transitional provisions.

How do residency and domicile shape your tax?

Where you are taxed, and on what, depends on residency and, historically, domicile. The UK determines residence through the Statutory Residence Test, counting days and ties in each tax year. The US taxes its citizens and Green Card holders on worldwide income no matter where they live, and also catches others through the substantial presence test.

From April 2025 the UK abolished the long-standing non-domicile remittance basis and replaced it with a residence-based four-year relief for foreign income and gains available to new arrivals. For anyone with international wealth, getting these positions right at the start of each year is the single biggest driver of an efficient outcome.

Positions we review each year

  • UK residence status under the Statutory Residence Test
  • US citizenship, Green Card, and substantial presence exposure
  • Eligibility for the UK four-year FIG regime post-April 2025
  • Treaty tie-breaker and foreign tax credit positions
  • Timing of income, gains, and remittances into the UK

How do you protect wealth across generations?

Estate planning across two tax systems is where errors become expensive. UK inheritance tax is charged at 40% on estates above the nil-rate band, with additional allowances for a main residence passing to direct descendants. US estate tax also reaches 40% once an estate exceeds the federal exemption, which is far larger but shrinks for non-US persons holding US-situated assets such as shares and property.

We build succession plans that use lifetime gifting, spousal and charitable exemptions, business and agricultural reliefs, life assurance held in trust, and the US-UK estate and gift tax treaty. For families with trusts, we align the settlor, trustee, and beneficiary tax treatment so structures created for protection do not trigger avoidable charges. The goal is simple: pass on more, with certainty, and without a compliance surprise for those you leave behind.

Because we handle both the personal returns and the estate strategy, every gift, trust distribution, and asset transfer is checked against IRS and HMRC rules before it happens, not after. That joined-up view is what separates genuine private client advice from single-country compliance.

Why Jungle Tax

One team for both sides of the Atlantic

Most advisers know either the IRS or HMRC. We work in both systems every day, so US and UK positions are planned together rather than stitched together afterwards. From London to New York and San Francisco, our private client team gives internationally mobile individuals and families a single, senior point of contact.

Speak to an Adviser
01

Dual-qualified thinking

IRS and HMRC rules considered side by side on every return, structure, and transaction.

02

Discreet, senior service

A dedicated point of contact for you, your family office, and your other professional advisers.

03

Trusts & estates depth

Specialist experience with cross-border trusts, settlements, and multi-jurisdiction estates.

04

Proactive planning

We review your position before each tax year, not after the numbers are already fixed.

Ready to plan your cross-border affairs?

Whether you are moving between the US and UK, planning your estate, or reviewing a trust, our private client team is ready to help. Arrange a confidential consultation today.

Private wealth and estate protection across generations
Private wealth

Protecting family wealth on both sides of the Atlantic

Cross-border families need a plan that holds up under both IRS and HMRC scrutiny. We structure investments, property, and succession so your wealth is preserved and passed on with certainty, coordinating every position across the US and UK.

  • Tax-efficient structuring of portfolios, property, and business interests
  • Estate and inheritance planning aligned across both jurisdictions
  • Trusts and settlements reviewed against US and UK rules
Confidential consultation with a private client tax adviser
Getting started

A single, senior point of contact for your affairs

From your first conversation, you work with an adviser fluent in both tax systems who coordinates your returns, planning, and other professional relationships. We review your position ahead of each tax year so decisions are made proactively, not after the numbers are fixed.

  • Discreet, dedicated support for you and your family office
  • Dual US and UK filings prepared and reconciled together
  • Proactive reviews before each tax year begins

Official resources & further reading

Authoritative guidance from the relevant tax authorities and regulators. Always confirm current thresholds and deadlines on the official source.

■ FREQUENTLY ASKEDQUESTIONS

Questions & Answers

Private client tax services provide individuals and families with tailored personal tax compliance and planning. For clients with US and UK interests, that means preparing IRS and HMRC returns, structuring wealth and trusts, managing residency and domicile positions, and coordinating inheritance tax, US estate tax, and remittance-basis planning across both jurisdictions in one coherent strategy.

You benefit if you are a US citizen or Green Card holder living in the UK, a UK resident with US assets or income, an internationally mobile executive, or a family with property and investments in both countries. Anyone facing dual filing, domicile questions, trusts, or cross-border estate planning needs an adviser fluent in both IRS and HMRC rules.

Domicile historically determined whether UK residents were taxed on worldwide income or only on UK income and remitted foreign income. From April 2025 the UK moved to a residence-based regime, replacing the non-domicile remittance basis with a four-year foreign income and gains relief for new arrivals. We assess your status and plan around the current rules.

Generally no. The US-UK double tax treaty and foreign tax credits are designed to prevent double taxation, letting tax paid in one country offset liability in the other. However, mismatches around pensions, capital gains, and certain investments can create traps. We coordinate both filings so credits are claimed correctly and exposure is minimised.

UK inheritance tax applies at 40% above the nil-rate band, while US estate tax can reach 40% above the federal exemption. Reliefs, lifetime gifting, trusts, spousal planning, and treaty provisions can all reduce the burden. We build an estate plan that works under both systems so your wealth passes efficiently to the next generation.

Yes. Trusts are powerful for succession and asset protection but are taxed very differently in each country, and offshore trusts carry complex reporting. We advise on establishing and reviewing trust structures, coordinate trustee compliance, and ensure US grantor and foreign trust rules align with UK settlements legislation to avoid unexpected charges.

Still have questions? We're here to help.

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