For London buyers considering Miami in 2026, ownership deserves attention before the purchase contract. The UK’s residence-based inheritance-tax framework, separate U.S. federal estate-tax exposure and treaty considerations make relocation only one part of the planning discussion.
For a London household considering Miami in 2026, the property search is also an ownership decision. A residence may become a seasonal retreat, a future principal home or an asset intended for the next generation. Each ambition calls for an ownership structure assessed across both jurisdictions, not chosen solely for ease of closing.
The central distinction is simple: buying a home in Florida and leaving the UK do not, by themselves, constitute a complete inheritance-tax strategy. From 6 April 2025, long-term UK residence replaced domicile as the principal connecting factor for UK inheritance-tax purposes. Foreign property, including a Miami home, can fall within that framework.
For a buyer considering The Residences at 1428 Brickell, the ownership conversation belongs alongside the Brickell property search, not after it. The address and the legal owner are separate choices.
The practical question behind the inheritance-tax tail is whether UK exposure continues after departure. A change of address is not proof that foreign assets have immediately left the UK tax net. Advisers should establish the buyer’s residence history, apply the long-term-residence rules and assess the position across the proposed relocation timeline.
That review should distinguish the UK domestic inheritance-tax test from treaty domicile and U.S. estate-tax residence. These are separate analyses. A conclusion reached for one purpose should not simply be carried across to another.
Nor should a household assume that all assets receive identical treatment once it is outside long-term-resident status. Non-long-term residents generally remain exposed to UK inheritance tax on UK assets, with additional rules for certain overseas interests connected with UK property. The Miami purchase belongs within a review of the wider estate, not in isolation.
Florida has no state-level estate tax for people who died after 31 December 2004. That is a meaningful distinction, but it does not resolve the federal position.
A non-U.S.-citizen, non-U.S.-resident decedent can face U.S. federal estate tax on U.S.-situated assets, including directly owned Florida real estate. For a household evaluating The Perigon Miami Beach, Miami Beach ownership therefore raises a federal question even though Florida itself has no estate tax.
Form 706-NA is generally required when such a decedent’s U.S.-situated assets exceed $60,000, subject to the applicable filing rules. That figure is a filing threshold-not the final tax bill or a shortcut to calculating liability. Deductions, credits and treaty provisions can affect the amount payable. The distinction matters when assessing the estate’s potential obligations, rather than merely the purchase budget.
Personal, joint, company and trust ownership should be compared as alternatives, not placed in a universal ranking. The discussion begins with the proposed owners, their relevant tax status and the family’s intended succession arrangements.
Direct personal ownership makes the underlying Florida real estate central to the U.S.-situs analysis. Joint ownership requires its own review; it is not an automatic escape from either jurisdiction’s rules. The question is how the proposed arrangement is treated, not simply whose names appear together.
Corporate ownership requires a separate situs analysis because company shares can be treated differently from directly owned U.S. real estate. That distinction warrants advice; it does not establish that any company structure is universally effective.
Trusts also require fresh scrutiny. The residence-based UK framework affects property settled when an individual was non-UK domiciled, so previous treatment should not be assumed to survive unchanged. An existing structure deserves review just as much as a newly proposed one.
A purchase at Ocean House Surfside may begin with a preference for Surfside. The inheritance discussion, however, should extend beyond the residence to the estate’s other assets and the owner’s circumstances.
Estate-tax valuation generally concerns fair-market value at death, not the original purchase price. A plan framed solely around the acquisition figure may therefore miss the relevant valuation basis. Buyers should ask advisers to distinguish the purchase budget from the estate-tax valuation question.
The U.S.-UK estate-tax treaty can affect taxing rights and double-taxation relief, but its application is fact-specific. U.S.-situated real property generally remains subject to U.S. taxing rights under treaty analysis. Treaty relief should therefore be evaluated, not presented as an automatic exemption for a Miami home. Equally, potential exposure in both countries should not be taken to mean a final double tax without that analysis.
A home initially intended for occasional use may later become central to family life. Whether considering Four Seasons Residences Coconut Grove or another Coconut Grove address, buyers should ask advisers to examine both the intended position at purchase and the position after a contemplated move.
A useful brief sets out the ownership options, the household’s residence history, citizenship, relevant estate assets and intended beneficiaries. It should identify which conclusions concern UK domestic inheritance tax, which concern U.S. federal estate tax and which depend on treaty analysis.
A clear brief makes the advice easier to revisit. Relocation should prompt a review of the original assumptions, not an automatic declaration that the work is complete. If the family’s plans change, the ownership discussion should change with them.
Before committing to an ownership arrangement, ask for a coordinated explanation of the proposed legal owner, the potential UK and U.S. exposure, the treaty position and the assumptions supporting each conclusion. Personal, joint, corporate and trust alternatives should be assessed against the same family objectives.
The aim is not to make tax the sole consideration in a residential purchase. It is to ensure that the home’s intended role and the succession plan have been considered together. For London buyers in 2026, Florida’s absence of state estate tax is one part of that picture, not its conclusion.
This article provides general information, not legal or tax advice; individual circumstances require qualified cross-border advice.
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Begin a quiet conversationLong-term UK residence replaced domicile as the principal connecting factor for UK inheritance-tax purposes. Foreign property can fall within the residence-based framework.
Yes. Foreign property, including a Miami home, can fall within UK inheritance tax under the long-term-residence rules.
Departure should not be treated as proof that foreign assets immediately leave the UK tax net. Advisers should assess residence history and the applicable rules across the relocation timeline.
Florida has no state-level estate tax for people who died after 31 December 2004. Separate U.S. federal estate-tax exposure can still apply.
A non-U.S.-citizen, non-U.S.-resident decedent can be subject to federal estate tax on U.S.-situated assets, including directly owned Florida real estate.
Form 706-NA is generally required when a nonresident, noncitizen decedent’s U.S.-situated assets exceed $60,000, subject to applicable filing rules. The threshold does not determine the final tax bill.
Estate-tax valuation generally concerns fair-market value at death rather than the original purchase price.
Not automatically. The treaty can affect taxing rights and double-taxation relief, but U.S.-situated real property generally remains subject to U.S. taxing rights.
No. Corporate ownership requires a separate situs analysis, and trust ownership should not be assumed to preserve previous UK inheritance-tax treatment.
Review ownership before purchase and revisit it after relocation. Personal, joint, company and trust arrangements should be compared against the household’s circumstances and succession objectives.
