Practice Area
Estate & Succession Planning
Cross-border trust structuring, international succession planning and multi-generational wealth transfer strategies for high-net-worth families with assets in Italy, the United States, the United Kingdom and beyond.
Who We Help
Is your estate situation one of these?
HNW Family with International Assets
Wealthy family holding real estate, financial assets and business interests across two or more jurisdictions, seeking a coordinated succession structure to minimise inheritance tax exposure.
Business Owner & Founder
Entrepreneur or company founder planning the succession of a privately held business — balancing operational continuity, family fairness and tax efficiency across generations.
US–Italy Cross-Border Family
Families with members resident in both Italy and the US, facing dual estate and inheritance tax systems, forced heirship rules and potential double taxation on the same assets at death.
Trust Settlor & Beneficiary
Individuals establishing or already benefiting from an offshore or domestic trust, seeking advice on tax transparency, Italian or US look-through rules, reporting obligations and trust governance.
01
Cross-Border Trust Structuring
A well-structured trust remains one of the most effective vehicles for cross-border estate planning, asset protection and succession. We advise on establishing and maintaining trusts in key offshore and onshore jurisdictions, selecting the appropriate governing law and ensuring compliance with Italian, US and UK tax reporting requirements for settled and transparent trusts.
- Jurisdiction selection: Jersey, Guernsey, Liechtenstein, BVI, Cayman, Delaware, Luxembourg
- Trust deed drafting coordination with local trustees and legal counsel
- Italian tax treatment: Art. 73 TUIR look-through for opaque vs transparent trusts
- US grantor trust rules (Sections 671–679) and foreign trust reporting
- Forms 3520 / 3520-A — US annual reporting for foreign trusts
- IVAFE and Quadro RW disclosure for Italian-resident beneficiaries
- Trust protector and letter of wishes drafting guidance
02
Italian Succession & Inheritance Tax Planning
Italy imposes inheritance tax (imposta sulle successioni e donazioni) on assets transferred at death or by gift, with rates from 4% to 8% and significant exemptions for direct-line relatives (€1,000,000 per heir). While rates are lower than the UK or US, Italian forced heirship rules (legittima) constrain testamentary freedom and require careful pre-death structuring. We provide comprehensive Italian estate advisory for residents and non-residents with Italian assets.
- Italian inheritance tax calculation and rate optimisation (4%–8%)
- Spousal and direct-heir exemption planning (€1M threshold)
- Forced heirship (legittima) analysis under the Italian Civil Code
- EU Succession Regulation 650/2012: law of habitual residence vs will choice
- Italian will drafting strategy: testamento olografo, testamento pubblico
- Pre-death gifting (donazione) to reduce taxable estate
- Italian succession declaration (dichiarazione di successione) filing
03
US Federal Estate & Gift Tax Planning
The US federal estate tax applies at a rate of up to 40% on estates above the exemption threshold (approximately $13.6M in 2024, scheduled to sunset to ~$7M in 2026 absent legislation). For non-US persons owning US situs assets, the exemption is only $60,000. We provide pre-mortem planning, trust structuring and compliance for US citizens, residents and non-residents with US estate exposure.
- Estate tax exposure analysis for US citizens, residents and NRAs with US assets
- 2026 sunset planning — use-it-or-lose-it lifetime gift exemption strategies
- Irrevocable Life Insurance Trust (ILIT) for estate liquidity
- Spousal Lifetime Access Trust (SLAT) and Grantor Retained Annuity Trust (GRAT)
- Qualified Domestic Trust (QDOT) for non-citizen surviving spouses
- US–Italy Estate Tax Treaty interaction and credit planning
- Form 706 and Form 709 preparation (estate and gift tax returns)
04
UK Inheritance Tax (IHT) Planning
UK Inheritance Tax is levied at 40% on estates exceeding the nil-rate band (£325,000) and residence nil-rate band (£175,000). Following the 2025 Non-Dom reform, the UK has moved to a residence-based IHT system: individuals resident in the UK for 10 of the last 20 years become “long-term residents” subject to worldwide IHT. We advise on UK IHT mitigation, trust restructuring and transitional planning under the new regime.
- UK IHT exposure analysis under the new 2025 residence-based rules
- Nil-rate band and residence nil-rate band optimisation (£500K combined)
- Business Property Relief (BPR) and Agricultural Property Relief (APR)
- Offshore trust planning under transitional provisions (formerly excluded property)
- Potentially Exempt Transfer (PET) seven-year gift strategy
- Spousal exemption and civil partner planning
- UK IHT–Italian succession double tax relief coordination
05
Family Foundations & Wealth Transfer Structures
Beyond trusts and wills, structured holding vehicles and private foundations offer powerful tools for multi-generational wealth preservation, philanthropy and succession planning. We advise on establishing and maintaining family foundations, private interest foundations and holding companies specifically designed for succession purposes across European and US jurisdictions.
- Luxembourg private wealth management company (SPF) and family SOPARFI
- Liechtenstein private foundation (Stiftung) — combined trust and foundation features
- Dutch STAK (Stichting Administratiekantoor) for business succession and governance
- Italian family pact (patto di famiglia) — tax-exempt inter vivos business transfer
- Delaware LLC and family limited partnership (FLP) for discounted valuations
- US Charitable Remainder Trust (CRT) and Donor-Advised Fund (DAF) for philanthropy
- Coordination of foundation income with beneficiary tax filings in Italy and the US
06
Family Governance & Generational Wealth Planning
Effective wealth transfer goes beyond legal documents. Multi-generational families need a governance framework that defines decision-making rules, manages family conflicts, prepares the next generation for stewardship and aligns financial strategy with family values. We assist in building family governance structures that sustain wealth — and family cohesion — across generations.
- Family charter and family constitution drafting
- Shareholders’ agreement and voting rights structuring for family businesses
- Family council and family assembly governance framework design
- Next-generation education and financial literacy planning
- Prenuptial agreement coordination (Italy, UK, US) for wealth protection
- Annual wealth review: asset consolidation, reporting and restructuring
- Coordination with family office, private bankers and investment managers
Jurisdiction at a Glance
Inheritance Tax: Italy vs US vs UK
Italy
- Rate: 4% (direct line) — 8% (others)
- Exemption: €1,000,000 per heir (children/spouse)
- Scope: Worldwide if Italian resident; Italian assets for non-residents
- Key issue: Forced heirship (legittima) limits testamentary freedom
- Relief: Donazione & patto di famiglia available
Low rates, but heirship rules must be managed
United States
- Rate: Up to 40% federal estate tax
- Exemption: ~$13.6M (2024); ~$7M from 2026 (sunset)
- NRA scope: US situs assets only; only $60K exemption
- Key issue: 2026 sunset will halve the exemption — act now
- Relief: ILIT, SLAT, GRAT, annual gifting ($18K/donee/year)
High rate; urgent 2026 planning window
United Kingdom
- Rate: 40% above nil-rate bands
- Exemption: £325K NRB + £175K RNRB = £500K combined
- Scope: Worldwide for long-term UK residents (10/20 years rule)
- Key issue: 2025 Non-Dom reform expanded worldwide IHT exposure
- Relief: BPR, APR, PET 7-year rule, spousal exemption
High rate; 2025 reform expands worldwide scope
Protect your wealth across generations.
Our cross-border estate specialists will map your exposure across every jurisdiction, model the tax cost of different structures and build a tailored succession plan that protects your family’s assets for the long term.
