Background
Parousia advised a UK-resident individual holding dual British and US citizenship, with substantial UK and international assets, on a complex programme of inheritance and estate tax planning.
The assignment required careful consideration of both UK Inheritance Tax and US estate tax rules, and particularly the interaction between the two jurisdictions — an area where planning that is efficient in one country can create exposure in the other.
The significant changes to the UK taxation of non-domiciled individuals taking effect from 6 April 2025 gave the work a firm deadline: certain aspects of the previous rules would cease to be available once the new regime began.
Our approach
Parousia reviewed the client's worldwide asset position and existing structures in advance of the new regime. This enabled appropriate planning to be considered and implemented while relevant aspects of the previous rules remained available, including the treatment of excluded property and arrangements involving non-UK resident beneficiaries.
Particular attention was given to asset ownership, residence and citizenship, the location of investments, and the client's longer-term succession objectives.
The advice also considered how steps taken for UK tax purposes could affect the client’s exposure to US estate taxation, so that neither jurisdiction was addressed in isolation.
Outcome
By coordinating the UK and US considerations and acting ahead of the legislative changes, Parousia assisted the client in mitigating potential inheritance and estate tax exposures.
The work also established an appropriate structure for the long-term preservation and succession of substantial international wealth.