Cross-Border Advisory
Cross-border tax advisory between the US and UK
Cross-border advisory is the planning layer above annual filing: treaty positions, pensions, business structuring and the timing decisions that only matter when the US and UK tax systems apply to you at once. It is where the real money is saved or lost — through reliefs claimed in the right order, elections made on time, and structures chosen with both systems in view. We provide it alongside the compliance work, so strategy and filing stay joined up.
Most tax problems between the US and UK are not filing errors — they are planning gaps. The return simply records a decision that was already made: how a company was set up, when a pension was drawn, whether a treaty position was claimed. By the time the return is due, the expensive choices have usually been taken.
Cross-border advisory moves the thinking upstream. It is the work of deciding how income, pensions, businesses and assets should sit across two systems before the event — so the treaty is used where it helps, elections are made on time, and reliefs line up rather than collide. We provide this alongside the compliance, because strategy that isn’t connected to the actual filings rarely survives contact with reality.
What we advise on
Cross-border advisory services
Treaty & Tax Planning
Structure income and assets to avoid double taxation.
Learn moreCross-Border Tax Planning
Coordinate income and reliefs across both systems before you file.
Learn moreBusiness Structuring
Set up UK companies the right way for US owners.
Learn morePensions (401k / SIPP)
How pensions are taxed across the Atlantic.
Learn moreWho this is for
- Individuals moving between the US and UK
- Americans with UK pensions or UK pensions with US members
- Founders structuring a company across both countries
- Families planning gifts, succession or estate exposure
- Anyone taking a decision that touches both tax systems
- Clients whose existing advisors need a US–UK specialist
How it works
A clear path, start to finish
Book a consultation
We map your situation and the cross-border decisions ahead.
Position review
We model the treaty, pension, structuring or planning options.
Clear recommendation
A written position you can act on, with the reasoning and risks set out.
Coordinated execution
We carry it through into your actual US and UK filings.
Investment
Bespoke, complexity-based pricing
Fees reflect the complexity of your situation — never a one-size template.
- £550 30-minute consultation
- Paid strategy session for detailed planning, credited to later work
- Written positions with reasoning, risks and reporting set out
- Advice coordinated into your real US and UK filings
Where a treaty position carries audit or disclosure considerations, we explain them plainly and recommend the conservative course unless your facts justify otherwise.
Explore related areas
Frequently asked questions
It is the planning layer that sits above annual compliance — deciding how income, pensions, businesses and assets should be structured when two tax systems apply at once. Rather than simply filing US and UK returns, cross-border advisory works out the positions, elections and timing that keep the two systems working together: claiming treaty benefits, coordinating pensions, structuring companies, and sequencing reliefs so you are not taxed twice.
Those services handle the returns themselves — your US filing, your UK Self Assessment, your company accounts. Cross-border advisory is the strategy that connects them: the treaty position behind a pension decision, the election that changes how a UK company is taxed in the US, the order in which reliefs are claimed. Most clients need both the compliance and the advisory, and we provide them together.
Before anything structural changes: moving country, taking a pension, starting or restructuring a company, selling property, or planning your estate. Advice taken before the event is almost always worth more than the same advice afterwards, because many cross-border positions — treaty elections, entity classifications, pension decisions — are far harder or impossible to fix once a return has been filed.
Yes. We frequently provide the specialist US–UK tax layer alongside wealth managers, solicitors and financial planners, coordinating positions across your wider professional team rather than replacing them.
Plan it before you file it
Book a consultation to get the cross-border strategy right before the decisions are locked in.