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US-UK Tax Talk

Author: Collyer Bristow LLP

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Welcome to US-UK Tax Talk,  brought to you by Collyer Bristow. Hosted by Aidan Grant, a Partner in our Tax & Estate Planning team, this series explores the complex world of cross-border tax and estate planning.


Aidan specialises in advising high-net-worth individuals with UK-US interests, including mixed-domicile marriages, UK-resident US citizens, and beneficiaries of US trusts. Named in Citywealth’s Top 100 Future Leaders, he brings expert insight and practical advice to every episode.


Join us as we engage with leading professionals across the UK and US, covering everything from wills and trusts to charity tax, and moving to the UK. Expect straight-talking discussions on English tax law - always with a US perspective.


Subscribe now and stay informed on the latest in UK-US tax and estate planning. For expert advice tailored to your needs, visit collyerbristow.com.


Disclaimer: This content is provided for general information only and does not constitute legal or other professional advice. Appropriate legal or other professional opinion should be taken before taking or omitting to take any action in respect of any specific problem. Collyer Bristow LLP accepts no liability for any loss or damage which may arise from reliance on information contained in this material.

52 Episodes
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In this episode of US-UK Tax Talk, host Aidan Grant welcomes back Patrick Mulhern, Partner at Tanager Wealth Management, for a deep dive into one of the most nuanced areas of cross border financial planning, investing for children where Americans are involved. Patrick first appeared on the show four years ago, and this return conversation explores how US and UK tax systems collide when parents and grandparents try to save and invest for minors. Americans living in the UK face a uniquely compl...
Welcome to US–UK Tax Talk. Host Aidan Grant is joined by Richard Taylor, founder of Plan First Wealth and host of We’re the Brits in America. Richard shares his personal journey from Manchester to Dubai to the US, and his professional insights as a financial advisor working almost exclusively with British expats in America. Together, they explore what moving to the US really looks like, beyond the clichés, and how to avoid costly financial missteps. This episode takes a hard look at the finan...
In this month’s episode, Aidan Grant is joined by Alicea Castellanos, Founder and CEO of Global Taxes LLC, to explore the complexities of US tax residency — including how individuals can unintentionally become tax residents and what this means for their global income, reporting obligations, and cross-border lifestyle. From citizenship and green card status to the Substantial Presence Test, Alicea explains the different ways residency can be triggered and why it is so often misunderstood. We d...
In the latest episode of US-UK Tax Talk, Aidan Grant is joined by Joshua Moss from W1M to explore the recently introduced Foreign Income and Gain (FIG) regime and the challenges faced by American expats adjusting to the UK's evolving tax landscape. Hear how FIG offers strategic opportunities for newcomers and returning residents to the UK, providing a four-year tax-free window, and the advantages of pre-arrival planning to ensure tax compliance and effective asset structuring under the FIG r...
For this month’s episode, Aidan Grant is joined by Charles Avens, Head of Immigration at Collyer Bristow, for a deep dive into the vast landscape of visa options available to Americans eyeing a move across the pond, and the risks and rewards they face when navigating UK immigration law. Discover the post-Brexit nuances of British citizenship and how citizenship opens a pathway to flexible travel to and from the UK. From citizenship by descent to the implications of future Commonwealth expansi...
On this month's podcast, Aidan Grant is joined by Gillian Everall, Founder & Managing Director of Everfair Tax Consulting Ltd, to discuss the complexities of US revocable living trusts, particularly for Americans with ties to the UK. Learn more about the recent changes in UK tax law, the uncertainty surrounding the treatment of living trusts, and the importance of forming a filing position. Explore how revocable living trusts serve as indispensable estate planning tools in the US, ...
In the first of our new monthly podcasts, Aidan Grant is joined by Bari Zahn, Founding Partner of Zahn Law Global LLC, to explore the complex world of real estate ownership for high-net-worth individuals. Bari, a US attorney with deep expertise in tax and estate planning, introduces the different ways property can be structured - direct ownership, LLCs, and various trust arrangements - highlighting the benefits, potential pitfalls, and tax implications of each. She reveals why many Americans...
Choosing the right wealth manager is about more than just numbers; it's about trust and communication. In this episode, Aidan Grant is joined by industry experts Martin Heale and Janette Saxer from Schroders Wealth Management to discuss the key factors in selecting a proactive and approachable wealth manager who can foster long-term relationships and weather the storm of challenging market conditions. This episode explores the nuances of obtaining accreditation and maintaining seamless advi...
What if the rules of tax and estate planning could be rewritten to better fit non-traditional families, particularly in the LGBTQ+ community? In this episode, Aidan Grant is joined by Ryan J. Coyle from Bilzin Sumberg to explore the unique challenges faced by LGBTQ+ individuals, especially Americans living in the UK. They highlight traditional tax laws that often prioritise married couples and explore how they impact those who don't fit this description. With the 2018 US tax reforms se...
In this episode, Aidan Grant is joined by Daniel Jaffe, Managing Partner at Jaffe & Co, to peel back the layers of the often-overlooked tax responsibilities that come with expat life. We explore the crucial question of who actually needs to file US tax returns while living in the UK and why overlooking this duty can lead to significant consequences. From income thresholds and foreign bank account reporting to the special case of "accidental Americans," this episode provides clarity...
In this episode Collyer Bristow's Aidan Grant was invited by Richard Taylor from Plan First Wealth to appear on its 'We're the Brits in America' podcast to discuss UK Domicile & Tax Changes: What you need to know about the changes to worldwide assets. We're the Brits in America Episode Description: There are tax changes coming in the UK - new rules replacing the domicile system with a tax residency-based system. This could affect your inheritance tax exposure, among others if you’ve been ...
Aidan Grant is again joined by guest Kristen Konschnik, Partner at London based US Law firm McLemore Konschnik. In this second episode of two, they dive deeper into tax considerations and practical solutions for charities and donors operating across borders.
Aidan Grant is joined by guest Kristin Konschnik, Partner at London based US Law firm McLemore Konschnik. In this first episode of two, they explore the intricate regulatory landscapes for charities in the US and UK. Stay tuned for Part 2, where we dive deeper into tax considerations and practical solutions for charities and donors operating across borders.
In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso to discuss how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the third of a three-part miniseries.
In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso to discuss how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the second of a three-part miniseries.
In this episode, Host and Partner Aidan Grant is joined by Senior Associate Emily Malvaso how the announcements in the Autumn Budget 2024 will impact families with US connections. This is the first of a three-part miniseries.
Aidan Grant is joined by Partner Jamie Austen in an Autumn Budget 2024 special. In the first episode they discussed their analysis and initial thoughts on the Labour government's Autumn Budget, announced on 30 October 2024. In this second episode of two, they examine changes to Capital Gains Tax, Inheritance Tax, and Agricultural Property Relief, along with their implications.
Aidan Grant is joined by Partner Jamie Austen in an Autumn Budget 2024 special to discuss their analysis and initial thoughts on the Labour government's Autumn Budget, announced on 30 October 2024. In this first episode of two, they provide initial comments on the Chancellor of the Exchequer's delivery of the Budget Statement to the House of Commons and the non-dom tax reforms it introduced. In the next episode, they'll examine changes to Capital Gains Tax, Inheritance Tax, and Agricultural P...
Aidan Grant and Nathania Hall continue their discussion on what Americans need to know about the UK probate process. In this second episode, they discuss the practicalities of UK probate in an American context including: why one might need a grant, the complexity of the process, and the circumstances where individuals might not need a grant of probate. (00:00) Introduction (00:35) Grant of probate discussion (01:12) Whether a grant of probate is necessary (04:05) Living trusts (05:45)...
Aidan Grant is joined by Senior Associate Nathania Hall to discuss what Americans with UK assets need to know about the UK probate process. In this first episode of two, they explain how UK inheritance tax applies, and what the tax filing process looks like for an estate. In the next episode, they will consider the complexities of a UK probate application for an international estate. (00:00) Introduction (01:29) Discussion on inheritance tax (12:26) When inheritance tax is due (14:07) How ...
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