JUNGLE TAX

Trusts & Estate
Planning

Securing the Future of Your Assets

Clarity for Your Family Legacy

Transferring wealth across international borders invokes a minefield of conflicting tax laws. A common UK discretionary trust can severely complicate affairs for a US beneficiary, triggering draconian IRS reporting rules and penalty taxes.

We provide absolute clarity. Working in tandem with your solicitors, our tax architects engineer robust estate plans. By carefully mapping domicile and leveraging US-UK Estate Tax Treaties, we ensure that the capital you build serves your family, not the tax authorities.

Defense

IHT & Estate Tax

Mitigating 40% UK Inheritance Tax and US federal estate taxes through structured lifetime giving, life insurance trusts, and domicile planning.

IHT ReliefEstate
Structure

Foreign Trusts

Advising grantors and beneficiaries on the implications of offshore structures, managing Form 3520 reporting to bypass severe penalties.

Trust Structuring
Assets Guarded
Business

Succession

Orchestrating the tax-efficient handover of commercial enterprises to the next generation using Business Relief and related strategies.

Administration

Probate Taxation

Supporting executors through periods of loss by managing the complex multi-jurisdictional tax filings required to unlock assets.

Consult
■ TRUSTS & ESTATE EXPERTISE

Our Capabilities

SERVICES
/ 01-Expertise 1

Inheritance Tax Strategy (IHT)

Navigating the punitive UK IHT regime and US Estate Tax limits. We analyze global assets to implement lifetime gifting strategies and domicile-based defenses.

Inheritance Tax Strategy (IHT)
/ 02-Expertise 2

Cross-Border Trust Structuring

Advising on the formation and taxation of foreign grantor and non-grantor trusts. We ensure compliance with onerous IRS forms (3520 / 3520-A) to prevent severe offshore penalties.

Cross-Border Trust Structuring
/ 03-Expertise 3

Succession Planning

Designing robust frameworks for passing family businesses to the next generation seamlessly, utilizing Business Relief (UK) and advanced valuation discounts (US).

Succession Planning
/ 04-Expertise 4

Probate & Estate Administration

Handling the complex tax filings required upon death for high wealth individuals with assets spanning multiple jurisdictions, ensuring smooth wealth transfer to beneficiaries.

Probate & Estate Administration
How We Work

Our Structural Process

01

Global Estate Mapping

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02

Domicile & Treaty Analysis

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03

Structuring & Execution

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04

Generational Oversight

Providing ongoing trusteeship tax reporting, adapting to changing family dynamics and inevitably shifting international tax codes.

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Peace of Mind

Specialist Architects of
Generational Wealth

Estate planning is fundamentally an exercise in foresight. Leaving cross-border wealth unguarded invites the harshest tiers of taxation from both the IRS and HMRC, potentially unwinding a lifetime of enterprise in a single generation.

Jungle Tax provides the elite level of guidance required to prevent this. We harmonize your long-term goals with intricate international law. Whether managing foreign grantor trusts or deciphering the US-UK Estate Tax Treaty, we ensure absolute compliance.

We work seamlessly with family offices, private banks, and legal counsel to execute holistic solutions, giving you the freedom to pass your legacy forward without erosion.

01

Multi-Jurisdictional

Ensuring your estate plan functions perfectly in both the US and the UK.

02

IHT Shields

Aggressive, legal mitigation of the 40% UK inheritance tax burden.

03

Trust Defense

Guarding against the severe IRS penalties associated with foreign trust misreporting.

04

Family Continuity

Securing the smooth transition of commercial assets down the bloodline.

Reach Out

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.

■ FREQUENTLY ASKEDQUESTIONS

Questions & Answers

UK Inheritance Tax (HMRC) is charged at 40% on the value of an estate above the nil-rate band, currently £325,000. US Estate Tax (IRS) applies to the worldwide assets of citizens above a federal exemption of around $15 million for 2026. The UK taxes largely on domicile, while the US taxes based on citizenship.

Potentially yes, because the US taxes citizens on worldwide assets while the UK taxes based on domicile and residence. Without planning, an estate could face both HMRC Inheritance Tax and IRS Estate Tax. The US-UK Estate and Gift Tax Treaty and available credits are used to prevent the same assets being taxed twice.

The treaty allocates primary taxing rights between the two countries, usually based on domicile, and provides credits so that tax paid in one jurisdiction offsets liability in the other. This stops the same assets being fully taxed by both the IRS and HMRC. Careful domicile analysis is essential to apply the treaty correctly.

A common UK discretionary trust is treated by the IRS as a foreign trust, triggering complex reporting on Forms 3520 and 3520-A. Distributions can be taxed under punitive throwback rules, and missed filings carry severe penalties. US beneficiaries of UK trusts need specialist coordination to avoid unexpected tax and penalty exposure.

Gifts made during your lifetime can fall outside your estate for Inheritance Tax if you survive seven years after making them, known as potentially exempt transfers. Gifts made within three to seven years may be taxed on a reducing scale called taper relief. Lifetime gifting is a core UK estate-planning strategy.

Yes. US persons who create, transfer to, or receive distributions from a foreign trust generally must file Form 3520, and the trust may need Form 3520-A. These reports are separate from your tax return and carry substantial penalties for late or missing filings, often starting at 35% of the amount involved.

Still have questions? We're here to help.

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Official resources & further reading

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