The United States and the United Kingdom have been described as two nations divided by a common language. Like our language, the establishment of New York’s common law is a legacy of our nations’ pre-revolution connections, but that too has evolved on both sides of the Atlantic to create distinct approaches to estate planning. A UK citizen with assets in or currently living in the US, or a US citizen living in the UK, needs to be aware of the difference in these approaches when preparing Wills and lifetime trusts to avoid an unexpected tax in one or both countries. Co-authored with Julie Jaggin of Mundays Private Wealth Team.