02Feb 2023 by Pat Geddie
Can Article 4 of the US-UK Estate, Gift, and Generation Skipping-Tax Treaty be Utilized to Avoid the U.K. Inheritance Tax?

Can Article 4 of the US-UK Estate, Gift, and Generation Skipping-Tax Treaty be Utilized to Avoid the U.K. Inheritance Tax?

Tax Law
By Anthony DiosdiThe United Kingdom or UK imposes an inheritance tax on the estate of deceased persons that were domiciled in that country. The tax rate is normally 40 percent. The inheritance tax is typically levied on estate values over 325,000 British Sterling Pounds or $402,000 U.S. Dollars. The UK inheritance tax on a decedent’s worldwide estate. A transfer of money or property from a U.K. spouse to a spouse domiciled in another country can also trigger the tax. Even if a person is domiciled outside the UK, two special rules apply to those who have emigrated from the UK or to those who have been resident in the UK for tax purposes for many years (IHTA84/S267). If either rule applies then, in most cases, HM Revenue & Customs may…
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04Mar 2021 by Pat Geddie
A First Impression of the Expatriation “Inheritance Tax”

A First Impression of the Expatriation “Inheritance Tax”

Tax Law
By Anthony Diosdi A record number of individuals have expatriated from the United States in 2020. For federal tax purposes, expatriation means 1) any United States citizen who relinquishes his or her citizenship or 2) any long-term resident of the United States who ceases to be a lawful permanent resident of the United States. The abandonment of citizenship or long-term residence may result in the assessment of the expatriation tax. This tax consists of the “exit tax” and the inheritance tax. This article will focus on the inheritance tax. An Overview of the Exit TaxThe Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART Act”) added Section 877A to the Internal Revenue Code. This code section imposes an exit tax on individuals who expatriate on or after June 17,…
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