Sheldrick & Co., PLLC.

UK Supreme Court Rules on Tax Treatment of LLCs

In a decision with potentially broad-ranging implications, the United Kingdom Supreme Court has overturned a longstanding practice of the UK tax authorities to treat U.S. limited liability companies as “opaque” entities. In Anson v. HMRC, [2015] UKSC 44, the Court ruled that a UK resident individual owning a membership interest in a Delaware LLC was entitled to credit the US Federal and State taxes he paid on his allocable share of the LLC’s profits, against UK tax payable on distributions received from the LLC. Our recent CaseNote examines the decision and its implications o for trans-border transactions involving LLCs.  Click here to read the article.

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