Family wealth that crosses a border needs translating, not just reporting.
Gifts between spouses, help onto the housing ladder, an inheritance from abroad, a trust set up by grandparents — ordinary family events, each read completely differently by the two systems.
Gifts are free in one direction only
The UK barely taxes lifetime gifts; the US tracks them against a lifetime exemption — and gifts to a non-citizen spouse lose the unlimited marital deduction. A large inheritance from a non-US person is tax-free but still reportable on Form 3520, with penalties for silence.
- Gift planning across both regimes
- Form 3520 for foreign gifts and inheritances
- Non-citizen spouse transfers, structured properly
- 529s, JISAs and children's accounts across borders
Trusts multiply the paperwork
A perfectly sensible UK family trust becomes a foreign trust the moment it touches a US person, triggering annual 3520/3520-A filings and throwback rules on distributions. We report what exists and restructure what should never have been built that way.
What we typically handle for you
- Cross-border gift planning and reporting
- Form 3520 for foreign gifts and inheritances
- Trust mapping and 3520-A where triggered
- Non-citizen spouse transfer structuring
- Children's accounts: 529s, JISAs, custodial
- Education funding across both systems
- Estate planning against both thresholds
- Coordination with your solicitors
The services that usually apply
Questions we get about this
If they are a US citizen and their income crosses the threshold, yes - including unearned income from savings or investments held in their name.
Custodial accounts and Junior ISAs frequently generate exactly this without anyone intending it.
The UK tax relief is real but meaningless to the IRS, and the funds inside are usually PFICs with heavy reporting.
Many families conclude the reporting outweighs the benefit and save for the child a different way.
They may well be a US citizen automatically, depending on the parent's own history of US residence.
Establishing this early is far easier than discovering it when they turn eighteen with years of unfiled returns.
If they are US citizens, potentially yes, once their income crosses the relevant thresholds - including unearned income from savings or investments held for them.
Children born abroad to a US parent are frequently US citizens without the family having thought of it in tax terms.
Receiving it is generally not taxable to you, but large foreign gifts and inheritances carry a reporting requirement.
The penalties for missing that report are meaningful even though no tax is due, which makes it an easy and costly thing to overlook.
They can be. Foreign trust reporting for US persons is heavy, and tax-advantaged UK savings wrappers give no US benefit while often holding PFICs.
Structures set up entirely sensibly under UK rules can read very differently to the IRS.
Last reviewed . Thresholds and rates change annually — check figures against the current tax year before relying on them.
Family with US connections?
Children, gifts and trusts all carry their own reporting. We will map what applies to yours.