US-UK Tax Talk

Collyer Bristow LLP
  • 5.0 (4)
  • Investing
  • Updated Monthly

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.

  1. Jul 1

    What Happens If You Run Your US Business from the UK?

    In this episode of US-UK Tax Talk, Aidan Grant is joined by Alex Straight, Partner in the US team at Blick Rothenberg, to discuss the tax and practical issues that arise when entrepreneurs and business owners run a business cross-border between the UK and the US. Aidan and Alex explore what happens when a US business owner moves to the UK and continues to manage or work for their business. They discuss central management and control, permanent establishment risk, and why a US company can accidentally become exposed to UK corporation tax, reporting obligations and Companies House disclosure requirements. The conversation also covers the use of UK subsidiaries, branches and employer of record arrangements, as well as payroll, PAYE, National Insurance and social security considerations for employees working across borders. Alex also explains why non-cash remuneration, share awards and deferred compensation can become particularly complicated when employees move between the US and the UK. 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, Collyer Bristow  https://collyerbristow.com/people-listing/aidan-grant/ 🔗 Alex Straight – Partner, Blick Rothenberg  https://www.blickrothenberg.com/ 🔗 Collyer Bristow  https://collyerbristow.com/ 🎧 Listen on the go  https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 Key Takeaways When should business owners start planning before moving to the UK? Ideally, planning should begin before the move takes place. Business owners need to understand not only their personal UK tax position, but also whether their activities could affect the tax residence, reporting obligations or structure of their business.What is central management and control? Central management and control looks at where the real strategic decision-making of a company takes place. If a US company is effectively managed and controlled from the UK, HMRC may treat it as UK tax resident.Why can central management and control be a problem? If a US company becomes UK tax resident, it may need to register in the UK, file accounts, disclose directors and beneficial owners, and potentially pay UK corporation tax. The US-UK tax treaty does not contain a simple corporate residence tie-breaker, which can create double tax risk.What is a permanent establishment? A permanent establishment can arise where a non-UK company carries on substantive business activity in the UK. This may include generating revenue, concluding contracts or having a dependent agent operating in the UK on behalf of the business.Why might a UK subsidiary be useful? A UK subsidiary can help ring-fence UK activity, manage local tax and reporting obligations, and limit the exposure of the wider US business. It can also provide a clearer structure for employees, customers, VAT, payroll and local compliance.What employment issues arise when someone works in the UK for a US business? Even where there is no UK subsidiary, a US employer may still need to consider UK payroll, PAYE, National Insurance, pensions and HR obligations if an employee is working from the UK. Employer of record arrangements may sometimes be used to manage these obligations.How can National Insurance and US Social Security interact? Employees working in the UK may be subject to UK National Insurance, although in some cases a certificate of coverage may allow them to remain within the US Social Security system for a period. This needs careful planning, especially for people moving later in their careers.Why do share awards and deferred compensation create extra complexity?Non-cash remuneration such as stock awards, RSUs and deferred compensation can be taxed differently in the US and UK. The tax treatment may depend on where the employee was working during vesting periods, what elections were made, and how the employer reports the award.

    What Happens If You Run Your US Business from the UK?

  2. Jun 3

    Private Equity Explained: From Deal Structure to Exit

    In this episode of US-UK Tax Talk, Aidan Grant is joined by Collyer Bristow partner Ragavan Arunachalam, Head of Private Equity, to explore the world of private equity, corporate acquisitions and dealmaking. Aidan and Ragavan discuss what private equity is, how it differs from venture capital, and why private equity investors are increasingly looking to the UK market. They explain how deals are structured, the role of debt and equity financing, and why management teams are often just as important as the capital being invested. The conversation also takes listeners through the lifecycle of a private equity transaction, covering heads of terms, due diligence, disclosure, deal documentation and completion. Along the way, Ragavan shares insights from more than 20 years of dealmaking experience and explains why successful transactions are often built on alignment, preparation and strong relationships. 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, Collyer Bristow https://collyerbristow.com/people-listing/aidan-grant/ 🔗 Ragavan Arunachalam – Partner, Collyer Bristow https://collyerbristow.com/people-listing/ragavan-arunachalam/ 🔗 Collyer Bristow https://collyerbristow.com/ 🎧 Listen on the go https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 Key Takeaways What is private equity and how does it differ from venture capital? Private equity generally involves investing in established, revenue-generating private companies, whereas venture capital is typically focused on earlier-stage businesses seeking capital to develop products, gain market traction or accelerate growth. Why are private equity investors increasingly attracted to UK businesses? Many investors see the UK as offering attractive valuations compared to other markets. This can allow capital to go further and create opportunities to acquire strong businesses with significant growth potential. Why do private equity firms use debt financing as part of acquisitions? Debt financing allows investors to leverage their capital and diversify risk across multiple investments. By combining debt and equity, investors can acquire larger businesses while preserving capital for other opportunities. What does due diligence involve in a private equity transaction? Due diligence is the process of investigating a target company’s legal, financial, commercial and operational position. It helps buyers identify risks, validate assumptions and understand how value can be created after the acquisition. What is the purpose of disclosure in a company sale? Disclosure allows sellers to identify exceptions to the warranties they give in the sale agreement. By providing buyers with complete information about known issues, disclosure helps allocate risk appropriately and reduce the likelihood of disputes after completion. Why is alignment between investors and management so important? Successful private equity transactions often depend on aligning the interests of investors, management teams and sellers. Equity participation and performance incentives can ensure everyone is working towards the same long-term objectives and eventual exit strategy.

    Private Equity Explained: From Deal Structure to Exit

  3. May 6

    How to Purchase UK Property as a Foreign Investor

    In this episode of US-UK Tax Talk, Aidan Grant is joined by Collyer Bristow colleague, Nick Mann, to help listeners understand the UK conveyancing process when buying or selling residential property. Aidan and Nick walk through the main stages of buying a UK residential property. They cover offers and acceptance, freehold and leasehold ownership, searches and due diligence, and exchange and completion. They discuss why international buyers can find the UK process unfamiliar, particularly because the transaction is not legally binding until exchange. 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, Collyer Bristow  https://collyerbristow.com/people-listing/aidan-grant/ 🔗 Nick Mann – Partner, Collyer Bristow https://collyerbristow.com/people-listing/nick-mann/ 🔗 Collyer Bristow  https://collyerbristow.com/ 🎧 Listen on the go  https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 Key Take Aways When does a UK property purchase actually become legally binding? An accepted offer is not legally binding in the UK and either party can still withdraw. The transaction only becomes binding at exchange, when contracts are signed, the deposit is paid, and the completion date is agreed. Why is it important to involve a solicitor early in the process? Early engagement helps identify risks, manage expectations on timing, and flag issues before costs escalate. It also allows buyers to understand restrictions, financing requirements, and whether the property meets their intended use. What is the practical difference between freehold and leasehold ownership? Freehold typically means owning both the property and the land, with greater control over what you can do with it. Leasehold usually applies to flats and involves a landlord relationship, ongoing costs like service charges, and restrictions on alterations and use. What does due diligence actually involve for a buyer? The solicitor reviews title documents, raises enquiries, and carries out searches such as local authority and environmental checks. This process highlights risks like planning issues, service charge liabilities, restrictions on use, or potential future costs. Why can the timing of a transaction be unpredictable? Factors such as property chains, mortgage approvals, search delays, and third-party responses can all affect progress. Buyers can only control their own readiness, so being organised and proactive helps reduce the risk of delays before exchange.

    How to Purchase UK Property as a Foreign Investor

  4. Apr 1

    New 2025 UK Tax Changes: What Americans Need to Know

    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.

    New 2025 UK Tax Changes: What Americans Need to Know

  5. Mar 4

    US Immigration: The Green Card Myth

    In this episode of US-UK Tax Talk, Aidan Grant is joined by Catherine Betancourt, a US immigration specialist at Flynn Hodkinson, to answer the practical questions people actually ask when planning a move to the United States. Aidan and Catherine walk through the typical US immigration journey from visas, to green cards, to citizenship. They cover what is realistic, what is commonly misunderstood, and where people get caught out. They discuss why work-based immigration often depends on having an overseas connection, why the H-1B is uniquely unpredictable, how family sponsorship works in practice, and why green card travel rules can become a major risk for UK-based lifestyles. 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/ 🔗 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 What are the main ways to move to the US if you’re not a US citizen? For most people it comes down to two routes: work or family. There is not, in the way people often assume, a simple “invest money and you get a visa” pathway. If you are not being sponsored through work or a qualifying family relationship, options narrow quickly.I’m a US employer (or I’ve got a US job offer). Why is it still so hard to get a visa? If the employer is US-only with no overseas footprint, the available visa routes can be surprisingly limited. Many common work routes are designed around a connection abroad, such as transfers. Without that link you are often pushed into more restrictive categories unless you qualify under something like “extraordinary ability.”Everyone mentions the H-1B. Is it actually a lottery and can you increase your chances? Yes. The H-1B begins with a genuine random selection lottery, and selection still does not guarantee approval. You also cannot “flood” the process with duplicates. It is one entry per applicant and duplicates can be disqualified, so it is not a reliable hiring strategy.If H-1B is uncertain, what are the realistic alternatives people actually use? Two of the most practical routes discussed are the L-1, moving someone from an overseas office to the US, and the E-2, a treaty-based business route that can work for UK nationals. Both can be effective, but both are highly fact-specific. The E-2 in particular can turn on ownership and nationality tracing.Once I have a green card, can I live outside the US and still keep it? This is where the rules tighten. Travel patterns can trigger scrutiny. Around six months abroad can lead to questioning at the border, and 12 months or more can be treated as evidence you have abandoned permanent residence. If extended time outside the US is likely, planning ahead and considering a re-entry strategy matters.

    US Immigration: The Green Card Myth

  6. Feb 4

    American Living In The UK? Estate planning traps to watch out for

    In this episode of US-UK Tax Talk, Aidan Grant, Partner in the Tax & Estate Planning team at Collyer Bristow, answers common listener questions on estate planning for Americans living in the UK. From wills and probate to living trusts, inheritance tax, family gifting, property ownership, and powers of attorney, Aidan explains when estate planning can stay simple, where cross-border complexity genuinely arises, and how US citizens in the UK can approach planning decisions with confidence. 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/ 🔗 Collyer Bristow – Tax & Estate Planning Team  https://collyerbristow.com/ 🎧 Listen on the go https://podcasts.apple.com/gb/podcast/us-uk-tax-talk/id1570411216 What’s Covered?  Does my estate planning have to be complex just because I’m an American living in the UK? Being subject to two tax systems does not automatically mean your estate plan needs to be complicated. Simple objectives can often be met with simple planning.I’m an American living in the UK with assets in both countries. Do I need a will in both jurisdictions? There is no fixed rule. The right approach depends on probate timing, cost, and administrative efficiency.A US attorney has recommended a living trust to avoid US probate, should I do that? US living trusts can be effective but are not always the right solution for UK-resident Americans and may create UK tax issues if used incorrectly.My estate planning wishes are simple, but I’m worried about UK inheritance tax, what can I do? Inheritance tax exposure can often be managed without over-engineering, but cross-border alignment is essential.My parents live in the US and want to make lifetime gifts to me. Are there UK tax issues? Yes. UK tax consequences can arise for UK-resident recipients even when gifts are made by US-based parents. My parents are redoing their US estate planning. Does my UK residence matter? Yes. The residence and tax position of beneficiaries can materially affect how US estate planning works in practice. My spouse and I are buying a home in the UK. I’m American, but my spouse isn’t,  should we think about ownership? Property ownership structure can have significant estate planning and tax implications for mixed-nationality couples.Should I put powers of attorney in place in both the US and the UK? Powers of attorney are jurisdiction-specific and often need to be put in place separately to be effective.I know I need advice, but who do I actually need - a lawyer, accountant, or financial adviser? Cross-border estate planning usually requires coordinated advice, and knowing who to involve is key.

    American Living In The UK? Estate planning traps to watch out for

  7. Jan 7

    UK Tax Audits and Investigations: How to Deal with HMRC

    In this episode of US-UK Tax Talk, host Aidan Grant is joined by James Austen, Partner, and Henry Lopes, Associate in the Tax & Estate Planning team at Collyer Bristow, for a practical and candid discussion on HMRC inquiries, tax disputes, and what taxpayers should do when things go wrong. Drawing on extensive experience in both tax advisory and litigation, James and Henry explain how HMRC inquiries arise, the different forms of non-compliance, and why cross-border taxpayers, particularly Americans living in the UK, are disproportionately exposed to investigation risk. The conversation explores how misunderstandings between the US and UK tax systems, especially around entities like LLCs and US trusts, often lead well-intentioned taxpayers into non-compliance. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Watch recent episodes on Collyer Bristow’s YouTube channel, and connect with our Tax & Estate Planning team. Key Take Aways Non-Compliance Takes Many Forms UK tax non-compliance is not limited to deliberate wrongdoing. It can include filing late, filing incorrectly, paying tax in the wrong country, or failing to disclose income due to misunderstandings between tax systems. Many US-UK issues arise despite good intentions. Cross-Border Taxpayers Face Higher Risk Americans in the UK often remain fully compliant with the IRS while unintentionally failing UK obligations. Structures like US LLCs and living trusts are common sources of inquiry because the UK frequently taxes them differently from the US. Seek Advice Immediately Once a taxpayer becomes aware of potential non-compliance, the clock starts ticking. HMRC may treat delays of as little as 3-6 months as careless conduct, increasing penalties. Prompt professional advice is critical. Going to HMRC First Matters Unprompted voluntary disclosure significantly reduces penalties. If HMRC contacts the taxpayer first, penalties can rise dramatically, in some cases up to 100% or more of the tax due. Disclosure Facilities Are Procedural, Not Lenient The Worldwide Disclosure Facility and Digital Disclosure Facility provide a method to disclose errors, but they do not offer penalty amnesties. Taxpayers typically have 90 days to prepare full disclosures, which is often much tighter than expected. Penalties Depend on Behaviour Penalties are driven by culpability: innocent error, carelessness, or deliberate conduct. Demonstrating cooperation, transparency, and prompt disclosure can substantially reduce penalty exposure. Litigation Is a Last Resort Most disputes settle through correspondence. Tribunal litigation is expensive, time-consuming, and uncertain. Even successful taxpayers usually cannot recover legal costs at First-tier Tribunal level. Record-Keeping Is Essential Taxpayers may need to defend returns going back up to 20 years in serious cases. Maintaining accurate, long-term records is crucial, even when issues arise decades later. Don’t Panic - but Don’t Ignore It Disagreements with HMRC are common in a complex tax system. With proper advice and a structured approach, even serious issues are usually manageable and less catastrophic than feared.

  8. 12/03/2025

    The Anson Case and How the UK Really Taxes LLCs with James Austen and Henry Lopes

    In this episode of US-UK Tax Talk, host Aidan Grant is joined by colleagues James Austen, Partner, and Henry Lopes, Associate in the Tax & Estate Planning team at Collyer Bristow, for a deep and detailed exploration of one of the most challenging areas of US-UK personal taxation: how the UK treats US Limited Liability Companies (LLCs) and why this continues to create double, and sometimes triple, taxation for American taxpayers living in the UK. While LLCs are a common planning tool in the United States and are generally treated as tax-transparent, the UK often takes the opposite approach, treating them as opaque corporate entities. This mismatch leads to substantial tax exposure for UK-resident members. Aidan, James, and Henry walk listeners through the legal characterisation issues, the risk of UK corporation tax, the complexities of the Anson Supreme Court case, and HMRC’s increasingly aggressive stance in the years since. Americans living in the UK face one of the most complex cross-border tax environments in the world, and when an LLC enters the picture, that complexity multiplies. Together, the team break down how differing legal systems, conflicting tax treatments, and HMRC’s updated 2023 guidance collide to create one of the most problematic issues in the US-UK tax world. Join us on the first Wednesday of every month for a new episode of the US-UK Tax Talk podcast, brought to you by Collyer Bristow. Watch recent episodes on Collyer Bristow’s YouTube channel, and connect with our Tax & Estate Planning team. Key Take Aways: Understanding the US-UK LLC Mismatch: In the US, LLCs are generally treated as tax-transparent, with profits flowing directly to their members. The UK, however, often treats LLCs as opaque corporate bodies, taxing the entity rather than the individual. This creates a fundamental mismatch, meaning income taxed once in the US may be taxed again in the UK without relief. Why Characterisation Matters: The UK must decide how to classify foreign entities that don’t have clear UK equivalents. LLCs sit at the centre of this problem. HMRC frequently argues that LLC income belongs first to the company, not the member, leading to double taxation regardless of how the US treats the same income. This characterisation question is central to every LLC case. Why Anson Doesn’t “Fix” the Problem: The 2015 Anson v HMRC Supreme Court case initially appeared to resolve the issue in favour of transparency. However, HMRC now argues that Anson was decided on narrow findings of fact and does not apply broadly. Updated 2023 guidance makes clear that HMRC considers most LLCs to be opaque, and the department is openly seeking a new “Anson 2” case to challenge taxpayers. Legal Analysis Is Essential: Successful reliance on Anson requires a two-part legal analysis: State Law Review: Does the LLC’s governing state law allocate profits directly to the members?Operating Agreement Review: Do the specific terms mimic transparency or suggest corporate-style decision-making?  Even small wording differences in an operating agreement can fundamentally change the tax outcome.Plan Before You File: Taxpayers are far better protected when they seek advice before filing their UK return. Legal opinions, proper documentation, and clear disclosure place taxpayers in the strongest possible position against HMRC challenges. Those who delay often face higher costs, greater risk, and the possibility of becoming HMRC’s next test case.

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About

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.

Information

  • Creator
    Collyer Bristow LLP
  • Years Active
    2021 - 2026
  • Episodes
    60
  • Rating
    Explicit
  • Copyright
    © 2026 US-UK Tax Talk
  • Show Website
    US-UK Tax Talk

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