Succession: United Kingdom → United States
Case complexity: low. The testator resides in United Kingdom, the heir resides in United States.
Which law decides who gets what
Under United Kingdom rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.
Who the law forces you to include
United Kingdom: Testamentary freedom; dependants may challenge inadequate provision under the Inheritance (Provision for Family and Dependants) Act 1975.
Where tax arises
United Kingdom: IHT 40% above the nil-rate band (£325k). From 6 April 2025 — residence-based: a long-term resident (10 of the last 20 years) is taxed on worldwide assets; a 3–10 year "tail" applies after leaving.
How it is recognised and processed
Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).
What to set up in advance
Will with a choice of applicable law
Private foundation
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This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.
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