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US LLCs and international groups


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?


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...

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