Providing answers to your queries on all aspects of personal and corporate taxation


United States

Are you a US Person Married to a Non-US Person?

If you are living outside of the US, setting up a foreign grantor trust with your non-US spouse as grantor can be used to minimise US tax exposure for US Beneficiaries receiving distributions or gifts from the trust.

If you are intending to move to the US then using a US compliant insurance policy - "A Variable Life Policy" can also assist in reducing US income tax exposures with regard to trust income.

Are you a Non-US Executive Married to a US Person?

Whilst still living outside of the US, developing a tax structure using trusts and offshore companies to hold share options will ensure that they are not subject to US tax upon your return to the US. Using a US Limited Liability Corporation can be a more tax efficient way of buying US property whilst resident in the US but you will need to be aware of the new IRS Treasury Regulations which require all foreign persons who own US property to provide a United States taxpayer identification number on all returns, statements or other required documents.


United Kingdom

Are you a UK person planning the most tax efficient way to retire?

When planning the most tax efficient way of taking income for retirement you can optimise UK income and tax allowances by using a trust structure for UK non-domiciled persons to hold property and investments whilst non-UK resident.

If you are a UK national but non-UK resident then using an offshore insurance bond (OLAB) can also help minimise your tax exposure. Providing you effect a policy via OLAB through an offshore branch more than six months before returning to the United Kingdom, you can keep the policy in force after your return and your investment will continue to grow free of UK tax right up to the time when the policy is encashed.