HMRC have issued updated guidance on the treatment of profits arising within, and distributions from, US LLCs. In a number of respects the updated guidance is unsatisfactory, coming in the midst of tax return preparation season, seeking to re-argue points that many will have considered settled by the Supreme Court’s decision in Anson v HMRC and raising the prospect of true double taxation as between the US and the UK.
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HMRC have issued updated guidance on the treatment of profits arising within, and distributions from, US LLCs. In a number of respects the updated guidance is unsatisfactory, coming in the midst of tax return preparation season, seeking to re-argue points that many will have considered settled by the Supreme Court’s decision in Anson v HMRC and raising the prospect of true double taxation as between the US and the UK.
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
