Glossary · Property & Estate
US–UK Estate and Gift Tax Treaty
A separate 1980 treaty (distinct from the income tax treaty) that allocates estate, gift, and inheritance tax rights between the US and UK using treaty-domicile tie-breakers. It survived the UK 2025 inheritance tax reforms.
In more detail
This treaty governs death and gift taxes, not income. It uses a treaty-specific concept of domicile to assign primary taxing rights and provide credits, preventing the same estate being fully taxed by both countries. For a US citizen who is not also a UK national, it can limit UK exposure and even shorten the post-2025 departure tail, though UK real estate generally stays within UK inheritance tax.
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