Graeme Privett

When you live, work, invest or retire across borders, managing your tax affairs can feel like navigating a legal minefield. For high-net-worth individuals with international ties, particularly between the UK and the US, dual taxation isn’t just a financial concern. It’s an emotional and mental burden, too. Even with tax treaties in place, the complexity of dealing with two tax regimes can quickly become overwhelming. And without joined-up advice, small mistakes can snowball into costly outcomes; missed deadlines, unexpected liabilities, and exposure to penalties that could have been avoided. So where do the biggest risks lie, and how can you protect yourself?

Over the 25 years that I’ve spent in the industry, I’ve worked with a host of individuals and families who have crossed the pond from the US to the UK. I was delighted to share my experiences in Atlanta recently, at the US Family Office Summit at the invitation of the UK Department of Business and Trade.

For many families, appointing a trustee has traditionally been about trust in the truest sense of the word. A trusted individual, often a family member or long-standing advisor, tasked with safeguarding assets and acting in the best interests of beneficiaries.

But in today’s environment, being a trustee is no longer a passive or occasional responsibility. It is an active role, increasingly shaped by complex tax rules, growing reporting obligations and heightened regulatory scrutiny. For some, it is beginning to feel like a full-time job.

In last year’s Budget, the Chancellor, Rachel Reeves, announced some sweeping changes to Inheritance Tax (IHT) affecting the farming community. We have seen tractors up and down Whitehall opposing these changes. However, these changes coming into force on 6 April 2026 go far further than has been appreciated and affect owner-managed businesses in every sector. The purpose of this insight is to explain what the law currently provides, what changes are due to come into force and what planning could be considered. If you are running a business valued at more than £1million on a hypothetical sale, you are affected by these changes and the window to act closes on 5 April 2026, which will be far sooner than you think.

Inheritance Tax (IHT) has always been one of the UK’s most politically sensitive taxes. It raises relatively modest revenues, yet provokes outsized debate. For families, it represents something far more personal than a fiscal line item: a direct intervention in how wealth, control and legacy are passed from one generation to the next.

Over the past decade, successive governments have tinkered at the edges of the IHT regime. Threshold freezes, new allowances, incremental reporting requirements and increasing scrutiny of reliefs have all added complexity without fundamentally reshaping the system. Now, with continued pressure on public finances and a renewed focus on perceived fairness, attention is once again turning to more meaningful reform.

For high-net-worth individuals, business owners and trustees, the key question is not whether IHT will change, but how to plan sensibly in a system that feels increasingly uncertain.