On 12 December 2023 HMRC issued updated guidance on the treatment of profits arising within and distributions from US limited liability corporations (LLCs) (see International Manual at INTM180000–180050). The guidance replaces the interim guidance which was issued in light of the Supreme Court decision in Anson v HMRC [2015] UKSC 44 (Revenue & Customs Brief 15/2015). We refer to the updated guidance as the 12 December guidance in the analysis below.
The Anson case had ramifications in a number of areas but at its heart turned on two questions: first under the terms of Delaware law and the relevant LLC agreement (which set out the key operating terms of the LLC) ...
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On 12 December 2023 HMRC issued updated guidance on the treatment of profits arising within and distributions from US limited liability corporations (LLCs) (see International Manual at INTM180000–180050). The guidance replaces the interim guidance which was issued in light of the Supreme Court decision in Anson v HMRC [2015] UKSC 44 (Revenue & Customs Brief 15/2015). We refer to the updated guidance as the 12 December guidance in the analysis below.
The Anson case had ramifications in a number of areas but at its heart turned on two questions: first under the terms of Delaware law and the relevant LLC agreement (which set out the key operating terms of the LLC) ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: