For a U.S. citizen who owns assets in both the U.S. and the U.K., integrated tax planning is critical. Even with effective planning, practical problems may arise in an estate as a result of fundamental differences in the way the two countries' probate and tax compliance systems operate.
There are plenty of potential traps for the unwary and, with such estates, it will be essential for advisors and attorneys on both sides of the Atlantic to keep a global perspective and to ensure that action taken in one country does not have unwelcome consequences in the other.
Dora Clarke is a partner in the London office of Withers LLP, an international law firm. She advises on all aspects of probate, succession and tax planning, often with an international element, particularly for high-net-worth families. For further information, visit www.withersworldwide.com or email Dora Clarke at [email protected].