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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
New 2025 UK Tax Changes: What Americans Need to Know
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In this episode of US-UK Tax Talk, Aidan Grant does things a little differently and becomes a guest on his own show. He is joined by Nathan Prior and Kat Smilewicz of Partners Wealth Management, with Nathan stepping in as guest host, to discuss what the UK’s 2025 tax changes mean in practice for Americans moving to the UK and for British expats returning home.
Together, they walk through the key issues that arise before and after a move to the UK. They cover UK tax residence, the new Foreign Income and Gains (FIG) regime, pre-arrival planning for trusts, companies and investment portfolios, and the opportunities and risks created by the Temporary Repatriation Facility. They also discuss why timing matters so much, why apparently simple money movements can create unexpected tax exposure, and why coordinated UK and US advice is often the difference between efficient planning and an expensive mistake.
Come back for new episodes of US-UK Tax Talk released on the first Wednesday of every month.
For questions or feedback, please contact us:
🔗 Aidan Grant – Partner, Tax & Estate Planning
https://collyerbristow.com/people-listing/aidan-grant/
🔗 Kat Smilewicz – Partners Wealth Management
Kat Smilewicz - Partners Wealth Management
🔗 Nathan Prior – Partners Wealth Management
Nathan Prior - Partners Wealth Management
🔗 Collyer Bristow – Tax & Estate Planning Team
https://collyerbristow.com/
🎧 Listen on the go
https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216
Key Take Aways
When do I actually become UK tax resident, and why does the start date matter so much?
UK tax residence is determined tax year by tax year under the Statutory Residence Test. That means if you trigger UK residence part way through a tax year, you can be treated as resident from 6 April unless split-year treatment applies. That start date matters because it can bring forward UK tax exposure and can also shorten the period during which you benefit from the new FIG regime.
What is the FIG regime, and who can benefit from it?
The Foreign Income and Gains regime was introduced from April 2025 and can give qualifying new arrivals a four-year exemption from UK tax on foreign income and gains. It is available not only to non-UK nationals but also to returning British expats, provided they have not been UK resident for four of the previous ten tax years. The rules are more objective than the old domicile regime, but the timing of arrival is critical because the four years run from the tax year of first UK residence.
What are the biggest traps people miss when bringing money into the UK?
A recurring theme is that US and UK tax rules often do not line up, even when the arrangements sound familiar. Money coming from a revocable living trust, an LLC, a parental loan, or the sale of US assets can have very different UK consequences from the US treatment people expect. That is especially important where someone is bringing funds to the UK to buy a home, because the source and route of the money can affect both immediate tax costs and longer-term inheritance tax exposure.
