Market leading insight for tax experts
View online issue

US LLCs and international groups

Question

 
A client is considering the restructuring of an international group which includes a US LLC in the group structure. What issues should the client be aware of?
 

Answer

 
A  US limited liability company (LLC) combines the limited liability of a corporation with the transparent tax treatment of a partnership or sole proprietorship for US tax purposes. 
 
UK tax treatment: case law
 
HMRC classifies entities as either ‘transparent’ (like a UK partnership) or ‘opaque’ (like a UK company) for UK tax purposes. The leading case was the Court of Appeal’s decision in Memec plc v CIR [1998] STC 754. In this case under the terms of a German silent partnership a UK company had a contractual right to receive the majority...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top