Inheritance Tax - Moved to USA

Дата публикации: 21-07-2026 17:28:40

*Has anyone dealt with UK inheritance tax after permanently moving to the US before the April 2025 rule changes?*
I'm hoping to hear from people with real experience (or professionals who have handled this).
My mother:
* Born and lived in the UK from 1941 until *June 2024*.
* Permanently moved to California in June 2024.
* Sold her UK home before moving.
* Owns only a California home (over 1MM) plus about cash in savings.
* Became a U.S. tax resident and files U.S. tax returns.
* Created a California *revocable living trust* in 2025 and transferred the house into it.
* The trust leaves everything to her USA based family
I'm trying to understand how the new UK inheritance tax rules work in practice.
Specifically:
1. Has anyone successfully argued that the *3-year rule* applies after leaving the UK before April 2025?
2. Has anyone had HMRC accept that they were no longer UK domiciled before the new rules took effect?
3. Has anyone had experience with the *US–UK Estate Tax Treaty* reducing or eliminating UK inheritance tax on a U.S. home?
4. Does a California revocable living trust make any practical difference for UK IHT?
5. Did anyone obtain a written opinion from a UK/US cross-border estate tax lawyer, and if so, what was the conclusion? Do you have recommendations on who to work with this on?

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