American Living In The UK? Estate planning traps to watch out for
Wed Feb 04 2026
In this episode of US-UK Tax Talk, Aidan Grant, Partner in the Tax & Estate Planning team at Collyer Bristow, answers common listener questions on estate planning for Americans living in the UK.
From wills and probate to living trusts, inheritance tax, family gifting, property ownership, and powers of attorney, Aidan explains when estate planning can stay simple, where cross-border complexity genuinely arises, and how US citizens in the UK can approach planning decisions with confidence.
Come back for new episodes of US-UK Tax Talk released on the first Wednesday of every month.
For questions or feedback, please contact us at usuktaxtalk@collyerbristow.com
🔗 Aidan Grant – Partner, Tax & Estate Planning
https://collyerbristow.com/people-listing/aidan-grant/
🔗 Collyer Bristow – Tax & Estate Planning Team
https://collyerbristow.com/
🎧 Listen on the go
https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216
What’s Covered?
Does my estate planning have to be complex just because I’m an American living in the UK? Being subject to two tax systems does not automatically mean your estate plan needs to be complicated. Simple objectives can often be met with simple planning.I’m an American living in the UK with assets in both countries. Do I need a will in both jurisdictions? There is no fixed rule. The right approach depends on probate timing, cost, and administrative efficiency.A US attorney has recommended a living trust to avoid US probate, should I do that? US living trusts can be effective but are not always the right solution for UK-resident Americans and may create UK tax issues if used incorrectly.My estate planning wishes are simple, but I’m worried about UK inheritance tax, what can I do? Inheritance tax exposure can often be managed without over-engineering, but cross-border alignment is essential.My parents live in the US and want to make lifetime gifts to me. Are there UK tax issues? Yes. UK tax consequences can arise for UK-resident recipients even when gifts are made by US-based parents. My parents are redoing their US estate planning. Does my UK residence matter? Yes. The residence and tax position of beneficiaries can materially affect how US estate planning works in practice. My spouse and I are buying a home in the UK. I’m American, but my spouse isn’t, should we think about ownership? Property ownership structure can have significant estate planning and tax implications for mixed-nationality couples.Should I put powers of attorney in place in both the US and the UK? Powers of attorney are jurisdiction-specific and often need to be put in place separately to be effective.I know I need advice, but who do I actually need - a lawyer, accountant, or financial adviser? Cross-border estate planning usually requires coordinated advice, and knowing who to involve is key.
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In this episode of US-UK Tax Talk, Aidan Grant, Partner in the Tax & Estate Planning team at Collyer Bristow, answers common listener questions on estate planning for Americans living in the UK. From wills and probate to living trusts, inheritance tax, family gifting, property ownership, and powers of attorney, Aidan explains when estate planning can stay simple, where cross-border complexity genuinely arises, and how US citizens in the UK can approach planning decisions with confidence. Come back for new episodes of US-UK Tax Talk released on the first Wednesday of every month. For questions or feedback, please contact us at usuktaxtalk@collyerbristow.com 🔗 Aidan Grant – Partner, Tax & Estate Planning https://collyerbristow.com/people-listing/aidan-grant/ 🔗 Collyer Bristow – Tax & Estate Planning Team https://collyerbristow.com/ 🎧 Listen on the go https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 What’s Covered? Does my estate planning have to be complex just because I’m an American living in the UK? Being subject to two tax systems does not automatically mean your estate plan needs to be complicated. Simple objectives can often be met with simple planning.I’m an American living in the UK with assets in both countries. Do I need a will in both jurisdictions? There is no fixed rule. The right approach depends on probate timing, cost, and administrative efficiency.A US attorney has recommended a living trust to avoid US probate, should I do that? US living trusts can be effective but are not always the right solution for UK-resident Americans and may create UK tax issues if used incorrectly.My estate planning wishes are simple, but I’m worried about UK inheritance tax, what can I do? Inheritance tax exposure can often be managed without over-engineering, but cross-border alignment is essential.My parents live in the US and want to make lifetime gifts to me. Are there UK tax issues? Yes. UK tax consequences can arise for UK-resident recipients even when gifts are made by US-based parents. My parents are redoing their US estate planning. Does my UK residence matter? Yes. The residence and tax position of beneficiaries can materially affect how US estate planning works in practice. My spouse and I are buying a home in the UK. I’m American, but my spouse isn’t, should we think about ownership? Property ownership structure can have significant estate planning and tax implications for mixed-nationality couples.Should I put powers of attorney in place in both the US and the UK? Powers of attorney are jurisdiction-specific and often need to be put in place separately to be effective.I know I need advice, but who do I actually need - a lawyer, accountant, or financial adviser? Cross-border estate planning usually requires coordinated advice, and knowing who to involve is key.