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Topic: Dual citizenship and inheritance  (Read 528 times)

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Dual citizenship and inheritance
« on: January 28, 2024, 09:19:28 PM »
What impact does inheritance from US have when you are a dual citizen living in UK ?

In particular:

-If I move back to US ,but still a UK citizen, is this problematic ?
-If I stay in UK for a few more years after the inheritance ( I have lived here 7.5 years so far) is this problematic? I don’t want to get taxed to death or run into other issues.
- I thought I read somewhere you have to have live in UK 15-20 years before this is problematic?
- any advice on this would be great as a starting point.

Many thanks!


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Re: Dual citizenship and inheritance
« Reply #1 on: January 28, 2024, 09:23:31 PM »
As far as I know the recipient of an inheritance has no tax implications in the US or UK. Any taxes on an inheritance is payable by the estate of the deceased, not by the beneficiaries.
Dual USC/UKC living in the UK since May 2016


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Re: Dual citizenship and inheritance
« Reply #2 on: January 29, 2024, 08:59:18 AM »
The United Kingdom does not charge tax on the receipt of an inheritance. The United Kingdom can charge tax on the receipt of distributions from US pension plans or trusts.


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Re: Dual citizenship and inheritance
« Reply #3 on: January 29, 2024, 01:03:07 PM »
The United Kingdom does not charge tax on the receipt of an inheritance. The United Kingdom can charge tax on the receipt of distributions from US pension plans or trusts.

Good thinking.  If the person has inherited an IRA then distributions from that IRA would likely be taxable in both the US and UK?
Dual USC/UKC living in the UK since May 2016


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Re: Dual citizenship and inheritance
« Reply #4 on: February 11, 2024, 01:27:12 PM »
Correct.  My inherited Roth and Ira distributions are taxed in the uk as income and the trad is taxed in the USA.  As my uk tax position is so high, I generally get the USA tax paid refunded. 


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Re: Dual citizenship and inheritance
« Reply #5 on: February 11, 2024, 01:50:48 PM »
Correct.  My inherited Roth and Ira distributions are taxed in the uk as income and the trad is taxed in the USA.  As my uk tax position is so high, I generally get the USA tax paid refunded.

I don’t believe you should be paying UK tax on Roth distributions as the treaty states that if retirement income is free of tax in the USA then it will be free of tax in the UK.
Dual USC/UKC living in the UK since May 2016


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