It is frequently assumed that the US - UK Treaty is rock solid in favour of the IRS in relation to English property jointly owned by a British deceased domiciliary, and reserves important taxing powers to the IRS over such items. It is important to read the Treaty in detail before acting on that assumption, in cases where the deceased had close links with the USA but died domiciled within the UK.

Peter Harris of Overseas Chambers has successfully advised a UK domiciled widow on attempted incursions into her jointly owned English property, and succeeded in negotiations with the IRS auditor in Miami to exclude the property from US estate duty under the Treaty and the Regulation.

Each case is different, but it would be unwise to pay over US Estate duty on an English jointly owned property without checking that it is actually due first.

Peter is available to take instructions on a direct access basis from executors, on a licensed basis from accountants, and other licensed professionals, and of course from solicitors in the usual manner.