A US Limited Liability Company (LLC) is treated as a partnership for United States tax purposes.  That is, a US person who is a member of the LLC has a direct interest in the LLC’s assets and activities. However, the tax treatment of an LLC for UK tax purposes has been debated. The ongoing test case is George Anson v HMRC (also known as Swift Case), which was found in favour of HMRC in the Court of Appeal in February 2013.  It was found in favour of HMRC in that it was held that US LLC’s are opaque for UK tax purposes,  in essence akin to a company for UK tax purposes.  The reason for this decision was primarily because the LLC could make its own decisions, independent of its members. We have advised a client in the past m...

Overview of Agricultural Property Relief Agricultural Property Relief (APR) is a very important inheritance tax relief. Where necessary conditions are met, relief is given in a similar manner to Business Property Relief (BPR) by reducing the value of the property being transferred for tax purposes potentially to nil.  The relief is available in respect of inheritance tax arising in respect of lifetime gifts, on death and periodic/exit charges of a trust. What is Agricultural Property The term agricultural property refers to land in the UK, Isle of Man, Channel Islands or EEA that is used for the purposes of agriculture and includes: farmhouses, cottage and buildings that are appropriate to the property, woodlands/buildings used...