I have a client who is a US citizen - deemed domiciled in the UK for IHT purposes.
Her net estate is well under U$5m so unlikely to pay any Federal Estate Tax on her death. She would like to set up some life insurance and write this into trust as there is an IHT charge in the UK on her death. She appreciates that the US may not recognise the Trust and include the policy in her estate for US Federal Estate Tax.
My concern is would she as a Settlor and possible Trustee of the Pilot Settlement have any tax/filing requirements during her life time in the US. I am sure that it would be best to get advice from a US advisor on this but thought I would lodge on the forum in case any of you have come across this and have some advice in this respect.
Mahendree Naidoo
Kingston Smith