This presentation is a U.S.-U.K. connected individual focused presentation and is particularly timely in light of the recently effective change to the U.K. tax regime (as of April 6, 2025). There is much attention currently on the U.K. changes and elimination of the remittance based regime and traditional "non-dom" and "excluded property trust" planning. However, there are interesting opportunities available under the U.S.-U.K. Treaty for U.S. persons who are not yet considered U.K. long term residents and thus, not yet U.K. domiciled.

This presentation focuses on the operation of the U.S.-U.K. Estate Tax Treaty, with a particular emphasis on the important exception in the Treaty for a U.S. domiciliary who creates a U.S. trust (with non U.K. assets) prior to becoming U.K. domiciled which is considered a settlement. Where as for man ...