Cross-Border Investments: HMRC Responds to U.K. Supreme Court Ruling That a Delaware LLC Is 'Tax-Transparent'

摘要

This article reports on a U.K. development of interest to U.S. companies and investors considering investing in them. The U.K. Supreme Court has given the final decision on the U.K. tax classification of a Delaware limited liability company (LLC), preventing double taxation of an individual investor, but raising questions for corporate groups holding such LLCs below U.K. companies; and the U.K. tax authority has issued guidance in response explaining how it plans to treat such LLCs in future.