Greenberg Glusker Private Client Services Chair, Laura Zwicker, and Private Client Services Partner, Stefanie Lipson, will present the below webinar for the Beverly Hills Bar Association from 12:30 - 1:30 p.m. on June 9, 2025.

A Battle With The U.K. Bare Trust—Let's Settle This Once And For All!

This presentation focuses on estate and inheritance tax planning under the U.S. – U.K. Estate Tax Treaty for U.S. – U.K. connected individuals. For many years, there was considerable focus when advising clients who might have U.K. domicile on ensuring a U.S. revocable trust was a bare trust for U.K. inheritance tax purposes. In light of the recent U.K. change (effective April 6, 2025) from a domicile-based to a long-term residency based inheritance tax regime, this presentation focuses on operation of the U.S. – U.K. Estate Tax Treaty, with particular emphasis on an important Treaty exclusion for non U.K. assets in a trust settlement created by a U.S. domiciliary who is not a U.K. national, which excludes the assets of the settlement from U.K. inheritance tax if the U.S. settlor later becomes a U.K. long-term resident and subject to U.K. inheritance tax after the date the trust is settled. The presentation also covers areas of potential double tax exposure where the Treaty may not assist, such as charitable gifts to organizations which are not both U.S. and U.K. qualified charities, further increasing the potential benefit of the Treaty’s settlement exclusion.

This presentation will be particularly relevant for attorneys advising U.S. individuals who reside or work extensively in the United Kingdom, as well as for legal practitioners who may be called upon to serve as trustees for trusts that are treated as settlements under U.K. law.

Laura A. Zwicker’s practice focuses on advising multinational and domestic families across generations on the tax, trust, and philanthropic issues involved in global and domestic wealth transfer. Laura provides tailored advice on tax residency and pre-immigration and emigration structuring, counsels founders on liquidity event planning, and serves as outside counsel to family offices and fiduciaries on a variety of planning issues, including the implications of family members and beneficiaries becoming U.S. tax resident. Laura partners with leading legal, tax, and family office advisors across Europe, Asia, Australia, and New Zealand, to ensure integrated structuring that best achieves clients’ objectives across jurisdictions. Laura has received many accolades, including being ranked in Band 1 in Chambers and Partners Global High Net Worth Guide (2016-2024) for Private Wealth Law.

Stefanie J. Lipson provides comprehensive tax counsel to domestic and international families and family offices, real estate and tech entrepreneurs, high-profile entertainment industry figures, private investors, and closely held business owners in all aspects of their family’s personal wealth and succession planning. Stefanie advises her clients in proactive wealth transfer, income, and property tax planning strategies, pre-liquidity and pre-acquisition transaction planning, and pre- and post-death administration, with focused expertise in generation-skipping transfer tax, planning with S corporations, California real property tax, privacy structures, and cross-border trust planning and residency issues. She is a frequent author and speaker on domestic and cross-border wealth transfer planning topics and has been recognized in Chambers' High Net Worth Guide in the area of Private Wealth Law and in The Best Lawyers in America.

Stefanie J. Lipson

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