US-UK Tax Talk

65 Episodes

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Legal Rights, Trusts and Property Tax: Planning in Scotland – with Susanne Batchelor

2026-11-0452:26

In this month’s episode of US-UK Tax Talk, Aidan Grant goes north of the border with Susanne Batchelor, Partner and Head of the Personal team at Brodies, to explore how Scottish law and tax differ from English law, and why that matters for US-UK planning. Aidan and Susanne start with the basics: the difference between the UK, Great Britain and England, and why Scotland, with its own legal system, courts and regulators, should be treated as a separate jurisdiction. They then look at Scottish s...

Pensions Lose Their Inheritance Tax Shield: Planning for April 2027

2026-10-0756:03

In this episode of US-UK Tax Talk, Aidan Grant welcomes back two past guests, Nathan Prior of Partners Wealth Management and Gillian Everall of Everfair Tax. They discuss the inheritance tax reforms for pensions due to take effect in April 2027, and what taxpayers should and shouldn't do before and after the changes arrive. Aidan, Nathan and Gillian start with why pensions have long been such tax-efficient vehicles: tax relief on contributions, tax-free growth and, for many people, the abilit...

Opening Doors: UK Banking Solutions for US Citizens

2026-09-0241:59

In this episode of US-UK Tax Talk, Aidan Grant is joined by Simon Gardiner, Senior Private Banker at Weatherbys, to discuss why Americans can find banking in the UK difficult—and how a relationship-led approach can help. Aidan and Simon explore why establishing a UK banking relationship can be valuable for Americans moving to, working in or spending significant time in the UK. They discuss currency exposure, overseas transaction fees, building a UK financial footprint and the practical diffic...

BONUS EPISODE: UK Tax Relief for US LLCs: Could HMRC Finally End Double Taxation?

2026-08-1951:27

In this special bonus episode of US-UK Tax Talk, Aidan Grant is joined by James Austen and Henry Lopes, Partners in the Private Wealth team at Collyer Bristow, to discuss HMRC’s consultation on the UK tax treatment of US LLCs. Aidan, James and Henry revisit the Anson case and explore why US LLC owners living in the UK can face economic double taxation. They discuss HMRC’s historic approach to LLCs, the new consultation on “reverse hybrids”, and why the consultation may offer cautious cause fo...

Equity Compensation Across Borders: Navigating US–UK Tax Rules for Shares, Options and Deferred Pay

2026-08-0551:09

In this episode of US-UK Tax Talk, Aidan Grant is joined by Michael Lewis, Partner in the US/UK Cross Border Tax Services team at EY, to discuss the tax issues that arise when US-connected employees in the UK receive shares, stock options, restricted stock units and other forms of deferred compensation. Aidan and Michael explore why ordinary cash remuneration is generally easier to manage across the two countries, and what changes when an employee receives non-cash or deferred awards. They di...

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