Creating a will as dual USC/UKC?

Does anyone have any advice for creating a will as a dual citizen residing in the UK? Most of our assets are in the US other than our house, we have two children in the US and one in Finland. Do we need a US and a UK will? And advice for avoiding the likely problems and taxation from inheritance?

(I realize this isn't quite US-UK Taxes, but this sub-forum seemed the best place for the question. )

Thanks, Jonathan

We have UK only wills, with the majority of our financial assets in the US. Our US financial accounts have our children as named beneficiaries which I believe takes precedence over any will, US or UK. I think the brokerage will only need copies of the death certificate along with letter from our lawyer to disperse the funds to our children.

Also, not sure of the legality of having 2 wills, each claiming to be the last will and testament.

You can and often you should have a Will for both countries. It's vital that one does not override the other though. Something along the lines stating that it only covers assets in the U.K. & visa versa for any U.S. Will.

If your assets can be POD/beneficiaries, then as durhamlad says, this would go directly to those outside of any Will. Real Estate, tangible property would benefit from a Will and a good lawyer in both countries. There is an inheritance tax agreement between the two countries, although NRA's with U.S real estate have lower thresholds.

It looks like Vanguard doesn't allow beneficiaries on joint accounts, which means we will have to handle the situation of both of us dying together via a will.

I found this article useful, and I'll post on this thread if I learn anything useful.

https://www.calprobate.com/blog/ensure-that-your-u-s-u-k-wills-dont-override-one-another/

It looks like Vanguard doesn't allow beneficiaries on joint accounts, which means we will have to handle the situation of both of us dying together via a will.

I found this article useful, and I'll post on this thread if I learn anything useful.

https://www.calprobate.com/blog/ensure-that-your-u-s-u-k-wills-dont-override-one-another/

Excellent article, thanks for that.

We each have a Vanguard Roth IRA which are, obviously, in separate names, and I removed my name from our taxable accounts before we moved to England because my wife had no other income so it maximizes her tax free allowances, both personal allowance and capital gains (about £25k).  Even if we were both in the same UK tax bracket then I would have split up the joint accounts into individual accounts to get around the beneficiaries problem and in our case we don’t have any tangible US assets other than bank accounts and the Vanguard accounts. (We each have a Wise bank account linked to our Vanguard accounts for easy transfer of money to the UK)

This is a problem for me as well - so Ive done nothing about it! The majority of my assets are in the US - Roth IRA, property, but I do have a SIPP and a current account in the UK. From what I've read I should do a UK will specifically saying this is only for the UK and for these two accounts, and do a separate will for the US, maybe referencing the other will and saying that handles the UK side of things?

R