IN THE PRESS: GERAINT DAVIES IN ‘THIS IS MONEY’ (MAIL ONLINE) – INHERITANCE TAX & USA

As one of the UK’s leading experts in cross-border financial advice, Montfort‘s Managing Director Geraint Davies, was recently called upon by This Is Money by Mail Online (Daily Mail) to respond to a reader’s question concerning inheritance tax implications between the US and the UK, and specifically an individual with autism and how they may financially prepare for a respective inheritance tax bill.

READER QUESTION: I WANT MY US-BASED SON TO INHERIT HIS FATHER’S UK FAMILY HOME: HOW CAN I ENSURE THIS HAPPENS?
“Our four-year-old son is autistic. We want to ensure he gets the family house in the future, but do not have the cash flow to pay for the inheritance tax bill. The house is worth around £1.3million, and the estate also includes a storefront with a flat above it worth £1.1million, and two flats worth £1million combined. I live with my son in the United States, but he is both a UK and a US citizen. His father lives in the UK, and the estate is in his mother’s name. She is 85 and is currently changing her estate planning. The shop and flat above it is under a limited company fully owned by my ex’s mother. Does the UK have protections for the disabled in estate planning, so that my son’s benefits are safeguarded and that he is properly looked after? The US does, but I’m not sure about the UK. If I were to die, my son’s guardians would be my extended family in the US rather than his father.”

Geraint Davies, replies: “Einstein reputedly said, ‘Make things simple, not simpler’. In other words, don’t bypass the complex to make it simpler. Please take professional advice, as the trusts and beneficiaries being based in different countries could create complexity.”

Geraint’s response demonstrates this is a complex cross-border case involving six individuals/entities across different countries, including a US-based single mother and her autistic child, UK property holdings, and guardians living abroad. Professional advice is essential due to differing laws and potential tax implications in each jurisdiction.

GERAINT’S RECOMMENDATIONS:

• Hold a family meeting to align goals and strategies, especially with the grandmother currently revising her estate plan.
• Plan for inheritance tax, especially since the mother lacks liquidity—UK law allows installment payments.
• Leverage UK–US tax treaties, but ensure tailored advice is sought.
• Understand disability trust protections, as benefits eligibility may still be impacted.
• Clarify tax treatment of inherited company shares in the US.
• Ensure open communication and transparency among all parties, which may be challenging due to geographical and relational divides.
• Coordinate estate planning efforts across jurisdictions to avoid uncoordinated decisions and negative outcomes.

The situation has been labeled a ‘Fisics’ case – Financially Impacted By Some International Checkpoints – highlighting the critical need for aligned, expert-led, cross-border planning.

To read the article in full, please click here. This Is Money is the online financial news and advice section of the Daily Mail newspaper website. A leading UK website focused on personal finance, offering news, advice, and tools related to investments, savings, mortgages, pensions, and more. The site’s mission is to help readers understand financial news and make informed decisions about their money.

If you would like to arrange a no obligation consultation with one of our advisers. please contact us via email info@montfort-intl.com or call 01483 202072.

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