Navigating US tax obligations can be complex, whether you’re an American citizen resident in the UK, a business owner looking to expand to the US, or a non-resident alien with US ties. 

The US taxes its citizens on worldwide income and capital gains, wherever they reside. For those living outside the US and paying tax in their country of residence, there is potential for double taxation without careful planning. 

Failure to complete correct tax returns and disclose foreign financial assets and certain foreign transactions can lead to disproportionate penalties.

S&W’s dedicated US/UK tax specialists provide tailored solutions to minimise your tax liabilities whilst ensuring your compliance obligations are met. 

Our dual US and UK tax professionals have a wealth of expertise navigating the complexities across both jurisdictions and can look after all aspects of your US and UK tax affairs under one roof.

Our US/UK tax services

Private individuals

Whether you’re an expatriate high net worth individual, a private equity executive with exposure to carried interest or someone going through a major life event, we can provide holistic support aligned with your ultimate, long-term objectives.

Our advisory and compliance services include:

  • Complex US and UK individual tax return compliance and reporting
  • US and UK tax residency advice, including using the Double Taxation Agreement to mitigate exposure
  • Investment account reviews for pre-entry planning
  • Foreign tax credit planning
  • Inbound and outbound US and UK tax planning
  • US and UK pension advice 
  • US and UK real estate and withholding implications
  • US streamlined filings
  • Expatriation and Green Card renunciation
  • Remittance planning for former residents and non-domiciled individuals 
  • Overseas workday relief claims 
  • Using the Temporary Repatriation Facility (TRF)
  • Using the new Foreign Income and Gains (FIG) regime for new residents 
  • US and UK divorce matters

Entrepreneurs

Setting up and running a business can be time consuming and complex, especially when there are cross border complexities where US owners are involved.

We help navigate the intricacies of US-connected individuals owning non-US business interests throughout the lifecycle of the business, ensuring compliance and tax efficient strategies are managed effectively. 

Our advisory and compliance services include:

  • US and UK tax efficient planning for owners and their businesses
  • US and UK tax structuring advice, including the use of US tax elections where appropriate
  • Business expansion into the US or UK and relocation of key personnel 
  • US and UK employee share schemes
  • The Controlled Foreign Corporation (CFC) regime, including navigation of Subpart F and/or Global Intangible Low Taxed Income (GILTI) (Net CFC Tested Income (NCTI) from 2026)
  • Passive Foreign Investment Company (PFIC) review and guidance

Trusts and estates

Managing family wealth and planning for future generations can be stressful tasks, but failure to do so effectively can result in significant tax consequences for US/UK families and beneficiaries.

We can help with succession, gifts and estate tax planning, working alongside lawyers where necessary to ease the burden and put in place tax efficient planning strategies to avoid unpleasant surprises.

Our advisory and compliance services include:

  • Cross border US estate and UK inheritance tax planning
  • Domestic trust US tax compliance
  • Foreign trust US tax compliance
  • Grantor and non-grantor trust compliance
  • US gift tax reporting
  • US estate tax reporting (including for non-resident aliens) 
  • Wealth and estate planning due to lifestyle changes such as marriage or divorce
  • US and UK tax implications for trusts, advising settlors, trustees or beneficiaries
  • Trust tax planning with US connected settlors or beneficiaries
  • US and UK tax planning for holding US situs assets
  • Comprehensive reviews of new and existing trust structures, identification of US tax considerations and planningPlanning and reporting for delinquencies surrounding trust structures

Contact Us

If you would like to discuss how we can help with your US/UK needs further, please contact Adam Smith (personal), Emily Walton (entrepreneurs) or Sarjul Patel (trusts and estates).