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.
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