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Home Property GuidesProperty Insights & Advice How to transfer ownership of UK property to a US-based heir

How to transfer ownership of UK property to a US-based heir

by John Saunders
10th Apr 25 11:36 am

Moving overseas makes family dynamics complicated at the best of times. But for those wishing to transfer property? You’ve just opened a whole new can of worms. Transferring UK property to a US-based heir is notoriously complex.

Rather than a simple question of standard inheritance tax, individuals must consider the complexities of navigating the UK and US tax systems. Transferring property might be more challenging with one party abroad, too. Have you ever tried to complete a house sale from overseas? It’s a roughly comparable concept; prepare for paperwork delays and hefty international phone call bills.

Here’s how to transfer UK property ownership to a US-based heir — without losing your mind in the process.

1. Understanding the legal process of transferring UK property

Take things back to the basics; understand the fundamental legal process before initiating any transfers. The simplest steps are as follows:

  • Establish the property’s current ownership status (ironing out the added complexity of a joint, not sole-owned property)
  • Update the Land Registry (if you haven’t done so already)
  • Change the registered owner’s name to that of your heir

Three steps might not sound too overwhelming, but they can become more complex with joint ownership. To transfer a joint-owned property, you’ll need to obtain a TP1 form to transfer part of the registered title, not a TR1, which involves the whole registered title.

2. Navigating tax implications in the UK and US

US and UK tax implications are tricky to navigate. Whether or not a property is taxed by both the UK and US is primarily dependent on the estate’s value. Typically, what qualifies a UK property for inheritance tax is considerably lower than what would qualify in the US.  The lifetime estate and gift allowance sits at nearly $14 million, as opposed to £325,000 in the UK. The good news is that most heirs will only be liable for UK tax fees.

It’s ill-advised to fall foul of international taxation laws, though. Speaking to a professional in cross-border transfers is wise. Inheritance tax could also vary based on US or UK domicile status (whether someone is considered a resident for the foreseeable, even if born abroad).

3. Seeking professional advice for cross-border transfers

With such subjective and individualised complexities, it truly is better to be safe than sorry. Consulting with cross-border estate planning professionals ensures you balance compliance with tax efficiency. Seek tailored guidance and actionable advice to protect your most precious assets. Ultimately, transferring a property is a significant lifetime milestone. Don’t let the nuances of Transatlantic property transfer ruin a momentous exchange.

With expert support, navigating the process of transferring UK property to a US-based heir is an easy bridge to cross.

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