UK tax treatment of US LLC: HMRC’s practice following Anson

October 01, 2015

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of profits of a US LLC. HMRC has now published its response to that judgment, confirming that, in general and subject to the specific facts, it will continue its long standing practice of treating US LLCs as companies.

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