CompanyShare Buy Back

A private company is looking to set up an insured buy back arrangement on death, but the problem is one of the minor shareholders lives in the US. For the purchase to be treated under capital gains rules the vendor must be resident or ordinarily resident in the UK (S220 TA). Which I assume means the purchase will be treated as a distribution in the hands of the estate in the US.

Anyone any ideas how this would work with a US purchaser?  Or does anyone know of a specialist in this area. Client is based in Sussex.