US-UK Tax Talk
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.
US-UK Tax Talk
Understanding the FIG Regime: A New Era for US-UK Taxation with Joshua Moss
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 regime.
From the reduced tax rate offered by the temporary repatriation facility (TRF) to the changing treatment of pensions under UK inheritance tax laws, we explore the critical role of wealth managers in advising clients amidst these sweeping changes. Discover the complexities of managing US investments, the implications of revised inheritance tax regulations, and how these changes affect estate planning strategies for international families residing in the UK.
This episode provides valuable insights into transitioning from the remittance basis to a more advantageous temporary repatriation regime, empowering expats to bring money into the UK at a reduced tax rate.
Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow.
Key Takeaways:
New Tax Regimes in the UK: Significant changes to UK tax rules, effective from April 6, 2025, include two notable regimes: the "Foreign Income and Gain Regime" (FIG), offering a four-year tax-free period for individuals new to the UK or those who have lived outside the UK for at least ten tax years; and the "Temporary Repatriation Facility" (TRF), allowing individuals previously on the remittance basis to bring their foreign income into the UK at a reduced tax rate of 12%-15%, rather than the higher default rates.
Impact on Cross-Border Wealth Management: These changes create new considerations for internationally mobile individuals and wealth managers. The flexibility and adaptability of financial planning now hinge on navigating these updated regulations and optimizing strategies for clients moving between jurisdictions.
Inheritance Tax Implications: The revised rules clarify the exposure to UK inheritance tax. Individuals residing in the UK for 10 out of the last 20 years are subject to inheritance tax on worldwide assets. However, during the first ten years, inheritance tax liability is generally limited to UK-based assets.
Strategic Financial Planning Adjustments: The FIG regime and TRF are game-changers for tax and financial planning. Clients relocating to the UK must reassess their asset management strategies within these frameworks. The TRF provides a window of opportunity for efficient repatriation of funds, which may require tactical planning to maximize benefits.
Complexities for US Taxpayers in the UK: Americans paying taxes in the US may face additional challenges with the FIG regime due to its accelerated reporting requirements compared to the previous remittance basis. This adjustment necessitates careful coordination between US and UK financial and tax considerations.
Chapters:
- 01:45 - Introduction to Tax Changes in the UK
- 18:33 - Understanding the New FIG Regime for American Expats in the UK
- 21:50 - Navigating the Remittance Basis and Tax Implications
- 36:17 - Inheritance Tax Planning and Its Implications
- 41:51 - The Implications of Pension Tax Changes
