This session provides an overview of recent UK residency and domicile changes affecting U.S. clients, with a focus on cross-border estate, trust, and tax planning considerations. The discussion highlights updates implemented in April 2025 related to the UK’s non-dom regime and examines statutory developments shaping future planning strategies. Attendees will also gain insight into potential reforms on the horizon, including anticipated changes to UK pension rules.
Intangible assets are now central to multinational business value, and recent policy changes have created significant incentives for businesses to centralise the ownership of intangible assets in the U.S. At the same time, foreign tax authorities are increasing scrutiny of cross-border structuring and transfer pricing. This session will provide a high-level overview of key concepts and planning considerations, including: the nexus with ‘DEMPE’ and ‘risk control’ functions, available tax incentives, withholding and foreign tax credit implications, and emerging enforcement risks affecting both routine ownership and use arrangements as well as the potential pitfalls of migration and ‘mischaracterization’ assertions from tax authorities.
