Specialist accountants for US and UK families

Specialist accountants for US and UK families

Wealthy families who operate across the United States and the United Kingdom face complex tax exposure. Multiple jurisdictions, different reporting systems, and conflicting tax rules create serious risks without careful planning. Many families turn to Specialist accountants for US and UK families when cross-border wealth structures become too complex to manage internally.

Family offices now play a central role in managing investment, governance, and tax strategy. Global transparency rules continue to expand, and authorities exchange financial data across borders. Families who ignore structural planning often face unexpected liabilities, reporting failures, and reduced efficiency in wealth transfers.

Why family office structuring matters in cross-border families

Cross-border families often hold assets in multiple jurisdictions. They may own operating companies, investment portfolios, real estate, and private equity interests across countries. Each asset may fall under different tax regimes.

Without a coordinated structure, income may be subject to double taxation. Reporting failures may also trigger penalties.

https://www.oecd.org/tax/automatic-exchange/

Global information exchange now allows tax authorities to access account data worldwide. This environment makes structured compliance essential.

Specialist accountants for US and UK families design coordinated structures that align investments, ownership, and reporting obligations.

Key objectives of a cross-border family office structure

Family office planning focuses on long-term wealth preservation. It also supports intergenerational planning, tax efficiency, and governance control.

A strong structure aims to reduce unnecessary tax leakage, maintain compliance across jurisdictions, and provide flexibility for future generations. It also helps families manage investments through a central decision-making framework.

https://www.gov.uk/inheritance-tax

Inheritance and estate tax rules vary significantly between the United States and the United Kingdom. A coordinated structure helps families avoid unexpected transfer taxes.

Specialist accountants for US and UK families often build structures that balance estate planning with ongoing investment efficiency.

The role of residency and domicile in family tax planning

Residency determines how authorities tax income and gains. Domicile rules also affect inheritance and estate taxes, especially in the United Kingdom.

Families with members in multiple countries must track residency carefully. A change in residency status may significantly shift tax exposure.

https://www.gov.uk/tax-foreign-income

United States citizens face worldwide taxation regardless of residence. This rule creates unique challenges for cross-border families.

https://www.irs.gov/individuals/international-taxpayers/taxpayers-living-abroad

Specialist accountants for US and UK families evaluate residency positions before implementing any structure. This step ensures the structure aligns with personal tax obligations.

Trusts and holding companies in family office structures

Trusts and holding companies form the backbone of many family office arrangements. These entities help separate ownership, control, and management responsibilities.

Holding companies may centralise ownership of operating businesses and investments. Trusts may support estate planning and protect assets across generations.

https://www.gov.uk/trusts-taxes

However, cross-border trust structures require careful planning. United States rules may treat certain foreign trusts unfavourably. United Kingdom tax rules may also apply anti-avoidance provisions.

Specialist accountants for US and UK families review trust structures to ensure they remain tax-efficient and compliant.

Controlled foreign company rules and family structures

Families often hold investments through foreign companies. These entities may fall under controlled foreign company regimes in both the United States and the United Kingdom.

These rules to prevent profit shifting to low-tax jurisdictions. They may require shareholders to report certain profits immediately.

https://www.irs.gov/businesses/international-businesses/controlled-foreign-corporations

The United Kingdom applies similar rules to those in place in the United States to capture diverted profits.

https://www.gov.uk/guidance/controlled-foreign-companies

Specialist accountants for US and UK families design structures that respect these rules while maintaining investment efficiency.

Managing cross-border investment income

Family offices often manage portfolios that generate dividends, interest, and capital gains across multiple jurisdictions.

Tax treaties may reduce withholding taxes on cross-border payments. Proper structuring ensures that families access treaty benefits.

https://www.irs.gov/businesses/international-businesses/united-kingdom-tax-treaty-documents

Treaty planning also supports the coordination of estate and gift taxes between countries.

https://www.oecd.org/tax/treaties/

Specialist accountants for US and UK families use treaty provisions to improve after-tax investment returns.

Governance and control within family office structures

A family office structure must balance tax efficiency with governance. Families need clear decision-making frameworks to manage investments and distributions.

Corporate boards, family councils, and trustee arrangements often form part of the governance structure. These mechanisms help prevent disputes and maintain strategic direction.

https://www.frc.org.uk

Good governance also supports regulatory compliance. Transparent structures reduce audit risk and strengthen financial oversight.

Specialist accountants for US and UK families often collaborate with legal and investment advisers to build governance frameworks that align with tax structures.

The impact of substance and transparency rules

Authorities increasingly examine whether family structures reflect genuine economic activity. Substance rules require real management presence and decision-making activity in certain jurisdictions.

https://www.oecd.org/tax/beps/

Artificial structures with no operational presence may face challenges or additional taxes. Families must ensure that structures reflect real governance and control.

Specialist accountants for US and UK families help families align legal structures with operational reality.

Estate planning across the United States and the United Kingdom

Estate and inheritance tax rules differ significantly between the two countries. The United States imposes an estate tax based on citizenship and domicile. The United Kingdom applies inheritance tax based on domicile status.

https://www.irs.gov/businesses/small-businesses-self-employed/estate-tax

https://www.gov.uk/inheritance-tax

Cross-border families must coordinate estate planning carefully. Without planning, assets may be subject to tax in both jurisdictions.

Specialist accountants for US and UK families design structures that support efficient wealth transfer across generations.

Reporting obligations for cross-border family offices

Family offices must meet extensive reporting requirements. These obligations may include foreign account disclosures, trust reporting, and corporate filings.

Global transparency initiatives now require financial institutions to share account data with tax authorities.

https://www.oecd.org/tax/automatic-exchange/

Families who ignore reporting obligations may face severe penalties. A coordinated reporting strategy reduces risk and maintains compliance.

Specialist accountants for US and UK families manage these obligations across jurisdictions.

How tax-efficient structuring supports investment growth

Tax-efficient structures improve long-term investment performance. Reduced tax leakage allows capital to compound more effectively.

Investors also prefer transparent and compliant structures. Clean tax records support investment partnerships and private equity participation.

https://www.federalreserve.gov

Specialist accountants for US and UK families often design structures that align tax planning with investment strategy.

The importance of early planning for cross-border families

Many families delay structuring decisions until wealth reaches a certain level. At that stage, restructuring becomes more complex and costly.

Early planning allows families to build efficient structures from the beginning. It also reduces compliance risks and improves long-term outcomes.

Specialist accountants for US and UK families provide forward-looking advice that aligns tax planning with family governance and investment strategy.

How JungleTax supports cross-border family offices

JungleTax works with high-net-worth families, entrepreneurs, and investors across the United States and the United Kingdom. The firm focuses on practical structures that balance compliance, governance, and tax efficiency.

Rather than offering isolated services, JungleTax provides integrated cross-border advice. This approach helps families manage wealth confidently across jurisdictions.

Experienced Specialist accountants for US and UK families at JungleTax guide clients through family office structuring, trust planning, treaty analysis, and ongoing compliance.

Build a structure that protects family wealth.

Cross-border wealth requires more than investment performance. It requires a structure that supports tax efficiency, governance, and intergenerational planning.

JungleTax Specialist accountants for US and UK families help families design structures that protect wealth and support long-term objectives. Contact the team at hello@jungletax.co.uk or call 0333 880 7974 to discuss your family office strategy.