Industry Conference
A Battle With The U.K. Bare Trust – Let’s Settle This Once And For All!
Greenberg Glusker Private Client Services Co-Chairs, Laura Zwicker and Stefanie Lipson, will present at the USC Gould School of Law Tax Institute on January 28, 2026.
Session Description:
This presentation focuses on the estate/ inheritance tax considerations for US-UK connected individuals, including trust funding during lifetime, risks of dual estate/inheritance tax, the US statutory credit against foreign death tax, a general review of bilateral transfer tax treaties, and specifics of the operation of the US-UK Estate Tax Treaty. The presentation also explores the increasingly important exception in the Treaty for a US domiciliary who creates a US trust (with non UK assets) prior to becoming UK long term resident, and covers mismatch areas where the Treaty may not assist, such as charitable gifts to entities which are not both US and UK qualified, and differences of availability of a US marital deduction and UK spousal exemption.
Resources