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US LLCs: tax issues for non-US members

Question

 
I am UK resident and UK domiciled and I am a member in a US LLC which carries on a trade in the US. Is this the best structure from a tax perspective? If not can it be converted into a better structure?
 

Answer

 
Current structure
 
A limited liability company (LLC) is a common business structure in the US. It is flexible to manage but it does create some tax issues for non-US members.
 
By default an LLC is treated as ‘transparent’ for US tax purposes similar to a partnership in the UK. This means that the members are taxed on the profits of the LLC (and must file US tax returns) rather than the LLC...
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