Garrington Property Finders: The New Architecture of Cross-Atlantic Relocation
The post-2024 period has brought a material increase in serious enquiries from American families contemplating a permanent or long-term move to Britain. The interest is not new, but its character has changed. The 2025 abolition of the non-domiciled tax regime, the shift to a residence basis for inheritance tax, and the continuing weight of Stamp Duty Land Tax surcharges for non-resident buyers have collectively redrawn the planning landscape for high-net-worth arrivals. The move has become considerably more demanding to execute well, and the consequences of doing it poorly have become more significant.
Jonathan Hopper, CEO of LPF Member Garrington Property Finders, has worked at the upper end of the UK residential market since 1996, advising buyers across London, the prime country house market, and internationally. In this piece, he sets out what the Anglo-American move now requires: the specialist architecture of immigration counsel, US-UK tax adviser, private client lawyer, and buying agent that must be assembled, carefully and early, on both sides of the Atlantic.
Special Relationships
The ‘special relationship’ is famously singular. The practical work of getting an American family from one side of the Atlantic to the other depends on the plural. Jonathan Hopper, CEO of Garrington Property Finders, on why the Anglo-American move has never required more carefully assembled relationships, on both sides, than it does today.
The mechanics of relocating from America to Britain, and the difference between doing it competently and doing it well, has been an active theme in Luxury Property Forum conversation for some time. The reason is straightforward. We have seen a material increase in serious enquiries from across the Atlantic, the UK regulatory landscape was substantially rewritten in 2025, and the practical reality of getting the move right has become considerably more demanding than it was even two years ago.
For more than half a century, the ‘special relationship’ has done its rhetorical work in the singular, a phrase deployed at summits, state dinners and editorial leaders alike. The version that matters to an American family actually crossing the Atlantic is rather different. It is plural, considerably less ceremonial, and the substance of it has changed materially over the last eighteen months.
The shifting ground
The volume of enquiries from across the Atlantic has increased noticeably. Whether driven by professional opportunity, family circumstance, the political climate of the moment, or simply the cumulative weight of wanting somewhere different, the post-2024 period has seen a marked uptick in serious enquiries from US buyers. The cohort is meaningful, and the practical infrastructure to serve it well is being tested.
The UK regulatory landscape has been substantially rewritten. From 6 April 2025, the United Kingdom abolished the historic non-domiciled tax regime that had governed the treatment of internationally mobile residents for over two centuries. In its place sits a new four-year Foreign Income and Gains (FIG) regime for qualifying new arrivals. Inheritance tax moved in the same direction, from a domicile basis to a residence basis, with significant long-term implications. The Stamp Duty Land Tax position for non-resident buyers, meanwhile, has not got easier. The combined effect is a fiscal environment that demands earlier and more sophisticated planning than was historically necessary.
The geopolitical backdrop is unsettled on both sides. Both the US and UK governments are mid-term, both have meaningful unexpired runways during which significant policy may yet move, and both operate against a backdrop of volatile global conditions. For families weighing a multi-million-pound property commitment, that uncertainty is not abstract. It is a live consideration informing whether to act now or take a more measured position.
The new tax landscape
The 2025 abolition of the non-dom regime has rattled internationally mobile buyers across the board, but the impact on US citizens is more nuanced than the headlines suggest. American citizens have always been taxed on their worldwide income by the Internal Revenue Service regardless of where they live, so the remittance basis was always less central to their planning than it was for other non-doms. The new four-year FIG regime offers a clean window of relief for qualifying new arrivals who have been non-UK resident for the previous ten tax years. For many American newcomers, it is more manageable than the regime it replaced.
The more consequential 2025 change for US clients is arguably the move to a residence basis for inheritance tax, which interacts in complex ways with the US estate tax regime and the US-UK estate tax treaty. The principle, broadly, is that once an individual has been UK resident for ten of the previous twenty tax years, their worldwide assets fall within the UK inheritance tax net, with a residual exposure of between three and ten years after leaving. For families with substantial assets on both sides of the Atlantic, that timeline matters and shapes long-term planning.
The point that follows from all of this is not that US arrivals need a tax adviser. It is that they need a particular kind of tax adviser, one who works specifically at the US-UK interface, who understands how the FIG claim mechanics interact with US Foreign Tax Credit positions, how the two systems treat trusts and pass-through entities differently, and how the inheritance tax frameworks need to be modelled together rather than separately. Generalist advice on either side is rarely sufficient.
The paperwork is the easier part
By comparison, the immigration position for American citizens is relatively straightforward and, with the right specialist help, rarely the source of the problems people imagine. US citizens have no automatic right to live and work in the UK. The two main routes for a permanent move are the Skilled Worker Visa, which requires a confirmed offer from a UK employer with a sponsor licence, and the Family Visa, for those joining a British or settled partner. The UK Ancestry Visa is not a route available to US citizens on the basis of a UK-born grandparent alone; it is restricted to Commonwealth citizens.
Since 8 January 2025, US citizens travelling to the UK for short visits or in transit need an Electronic Travel Authorisation (ETA) in advance of arrival. The ETA is not a visa, costs £20 at present, and remains valid for two years. It is one of the small but easily missed details of the modern UK arrival.
The wider observation is that immigration is much more manageable when addressed early and with proper specialist input than when left until late in the process. Specialist immigration counsel is the prudent baseline for high-net-worth arrivals.
Where to live, and how to choose
Britain contains a great deal of variety, and the question of where to live is where conversations with US clients most often start. We tend to work through three questions: where you need to be for work, how much space matters, and how important proximity to London or an international airport is. From those three, a shortlist of regions usually emerges quickly.
London remains the natural choice for many, and for very good reason. For those in corporate or financial roles, or for families who want to be embedded in a global professional and educational network, the connectivity is unrivalled. Direct flights to most major US cities, a genuinely international business infrastructure, and a concentration of advisers and institutions that understand the cross-Atlantic position make it the most practical base for those whose lives still substantively touch the United States.
For those whose priority is space, countryside access, or simply a setting that feels more decisively British than the capital, the search extends further afield. The Cotswolds has become one of the most consistent draws among the American families we advise, where village life meets the school-and-airport infrastructure that wider families require. Cambridge and Oxford retain a particular pull for academic and professional families, with rail connections to London faster than American buyers typically expect. The historic cathedral cities such as Winchester offer outstanding schools within striking distance of the south coast. And we have seen markedly increased American interest in parts of Scotland over the last eighteen months, both in Edinburgh and across the Highlands, drawn by a combination of heritage, landscape, and what is, by London standards, significant relative value.
The deeper point is that the right answer is intensely personal.
The architecture of the transaction
This is the area where American buyers are most frequently caught off guard, and where the structural differences between the US and UK systems are most consequential. The detail that follows describes the position in England and Northern Ireland, where the majority of US property purchases land; Scotland and Wales operate distinct legal and tax regimes that warrant separate specialist advice.
In the US, buyer representation is standard. In England, the estate agent is instructed by, and works for, the seller. Unless a buyer specifically appoints a buying agent to represent their interests, they are navigating an unfamiliar market without an advocate, often from several time zones away. A well-connected buying agent also provides access to the part of the market not visible on the property portals, which at the upper reaches of the prime market now represents the majority share.
The transaction structure itself has no built-in equivalent of escrow. The period between agreeing a price and exchanging contracts, during which either party can withdraw without penalty, can run for several weeks or longer. For a buyer who has relocated and is waiting to complete, that is a meaningful vulnerability, and a well-managed legal process is what closes the gap. The leasehold and freehold distinction deserves careful attention too; the details of an older lease matter and need to be properly understood before commitment.
The Stamp Duty Land Tax position is where the numbers become eye-watering. A non-UK resident buyer pays a 2% non-resident surcharge on top of standard SDLT, and an additional 5% surcharge if the property is not their only or main residence. For an American buying a £2 million London home as a second residence, the SDLT bill is approximately £294,000 once both surcharges are stacked on the standard rates, around 14.7% of the purchase price. The 2% non-resident element may be reclaimable if the buyer subsequently satisfies the relevant UK residence test within twelve months of purchase, but the 5% additional dwelling element generally cannot.
The currency picture is its own consideration. Sterling rallied against the dollar through 2025, but the cable rate remains materially below its pre-2016 trading range, and the volatility of the rate has continued to create tactical opportunities for disciplined dollar-backed buyers. Currency can move against buyers as well as in their favour, and many American clients now stage their conversions or use forward contracts to manage their exposure rather than committing the entire purchase price at a single point in time.
The case for renting first
Set against this backdrop, an increasing number of HNW US arrivals are opting to rent in the first instance rather than commit to a purchase at the moment of arrival. The logic is straightforward. The transaction costs of buying as a non-resident are at historically high levels. Both the US and UK political pictures retain meaningful unexpired runway. The decision of where exactly to settle is often easier after a year of living in the country than before it. And in a market where the prime property landscape itself is shifting, the option value of waiting can be considerable.
A twelve to twenty-four-month rental position, in a property that meets the family’s actual lifestyle needs, allows the move to settle, the tax position to be modelled in practice rather than in projection, and the property search to be pursued from inside the market rather than from across the Atlantic. For families whose move involves significant uncertainty, where employment may evolve, children’s education is settling, or a sense of place has yet to crystallise, the rental route is increasingly the strategic choice rather than the fallback.
It also tends to make for a better eventual purchase. Buyers who have lived in the country, walked the school routes, and learned which neighbourhoods sing on a Tuesday evening rather than only on a sunny Sunday are buyers who know what they want. That clarity is worth a great deal.
The advisers around the move
The architecture of a serious Anglo-American move now depends on a carefully chosen set of specialist advisers, each selected for genuine cross-border experience rather than general competence. There are typically four or five points in the constellation. Specialist immigration counsel handles the visa route and arrival timing. A US-UK tax adviser navigates the FIG claim, the residence-based IHT position, and the interaction with US Foreign Tax Credits. A UK private client lawyer manages long-term estate and trust planning. A property lawyer handles the transaction itself. And a buying agent represents the client throughout the property search and acquisition, ensuring access to the part of the prime market that is not publicly marketed.
The point is not that any of these roles is novel. The point is that the consequences of working with a generalist in any one of them have become significantly higher. The FIG claim mechanics, the residence-based IHT regime, the SDLT surcharges, the immigration timing windows, and the property transaction structure each carry enough specialist content that the wrong adviser in any seat can derail a great deal. Each professional needs to be operating in concert with the others, not in isolation.
This is what we mean by special relationships in the plural. The diplomatic singular describes state-to-state alliance. The practical plural describes the people assembled around a serious cross-Atlantic move, the cumulative architecture that determines whether the move comes together well or comes together at all.
What has changed in 2026 is not the principle but the stakes. The principle remains that getting the architecture right before the move begins is what separates the moves that work from those that drift. The architecture is built on relationships, specific, considered, properly chosen relationships on both sides of the Atlantic, and putting those in place is the first task for any American family seriously contemplating a British move. The diplomatic phrase is famously singular. The practical work, when it comes together well, is comfortably plural.
Jonathan Hopper is CEO of Garrington Property Finders, a UK-wide buying agency specialising in the prime residential market. Garrington has worked with high-net-worth and ultra-high-net-worth buyers across London, the prime country house market, and internationally since 1996, including substantial US clientele.
About Garrington Property Finders
Garrington Property Finders is a leading UK Property Finder. We offer expert advice and property search services to clients wishing to acquire private residences, second homes, or properties for rental or investment and on many occasions before a property has come onto the open market. Our property search consultants have unparalleled specialist knowledge of their local markets, together with an extensive network of professional contacts. Time is spent carefully listening and understanding each client’s unique property requirements to ensure that exceptional results are delivered. Spanning over 16 years as a market leader, Garrington is one of the most established independent home finders in the UK.
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To find out more about Garrington Property Finders, please contact the team using the details below:
T: +44 (0)20 7099 2773
Visit their website: www.garrington.co.uk