US LLCs may face tougher treatment in the UK
March 31, 2010
The first-tier tax tribunal in the UK has cast doubt over the UK tax treatment of US limited liability companies (LLCs) in the decision Mr Swift v The Commissioners for HMRC ([2010] UKFTT 88 (TC)).
The Swift case centres on whether the profits of an LLC when in the hands of UK resident members, are eligible for double tax relief on the US tax already paid.
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