Legal Guidance and Research / Experts / Martin Scullion
Martin Scullion#6127
LinkedIn

Martin Scullion

Year of Qualified: 2001 (UK) and 2009 (US)

I act as an adviser to Americans in the UK and a number of trust companies providing US/UK tax advice and compliance services. My clients comes from a wide range of backgrounds and include non-doms, US citizens, US green card holders, US residents, in addition to trustees, settlors and beneficiaries of offshore trusts.

Practice Area

Panel

  • Contributing Author

Qualified Year

  • 2001

Membership

  • Society of Trust and Estate Practitioners (STEP)
  • Association of Taxation Technicians (ATT)
  • U.S. Department of the Treasury
  • Internal Revenue Service (IRS)

Education

  • University of Strathclyde

1 Contributions by Martin Scullion

UK-US cross-border estate planning after April 2025: UK IHT long-term residence, US estate/gift/GST, QDOTs, excluded property trusts, and treaty domicile tie-breakers, credits and reliefs
PRACTICE NOTES
UK-US cross-border estate planning after April 2025: UK IHT long-term residence, US estate/gift/GST, QDOTs, excluded property trusts, and treaty domicile tie-breakers, credits and reliefs
Complex US and UK tax issues for estates UK practitioners frequently face scenarios in which intricate US and UK tax questions arise for estates of the deceased who were domiciled in the UK at death, and for estates exposed to US estate tax through citizenship or domicile. Further complications occur where the deceased owned property situated in the US or the UK at the time of death. From 6 April 2025, UK inheritance tax (IHT) will be determined by a new long‑term residence concept rather than domicile or deemed domicile. Under this rule, an individual who has been UK resident for 10 of the previous 20 tax years will be treated as a long‑term UK resident (LTR) and subject to IHT on worldwide assets — see Practice Notes: A new residence‑based regime for IHT from 2025–26 and New IHT regime from 6 April 2025—FAQs. Before this change, domicile (or deemed domicile) determined IHT exposure — see Practice Notes: Deemed domicile for tax before 6 April 2017 [Archived] and Deemed domicile for tax from 6 April 2017 to 5 April 2025 [Archived]. Domicile, however, remains a crucial factor for US/UK estate tax treaty purposes, and UK practitioners will continue to face complex issues where...
Private Client
Expert page AD
If you expected to see yourself on this page, click here.