News & Analysis as of

Limited Liability Company (LLC) United Kingdom

Walkers

Update on changes to the beneficial ownership regime in the Cayman Islands

Walkers on

Changes to the beneficial ownership regime took effect on 31 July 2024 and enforcement relating to the new requirements is suspended until early 2025. Many entities that previously had few or no obligations will have to...more

Akin Gump Strauss Hauer & Feld LLP

EU Publishes New Best Practices Guidance, including Updated Ownership Test and Additional Control Guidance

Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more

Proskauer Rose LLP

UK Tax Round Up - December 2023

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Welcome to December’s edition of our UK Tax Round Up. This month has seen two interesting decisions on the connections needed for amounts to be taxed as employment income, the latest instalment in the BlueCrest partner...more

Proskauer - Tax Talks

HMRC updates guidance on UK tax status of non-UK entities and US LLCs post Anson

Proskauer - Tax Talks on

On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and other US) limited liability companies (LLCs) in particular (in INTM180000...more

Cadwalader, Wickersham & Taft LLP

Perfect Influence?

In HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 00232 (TCC) (“HMRC v BlueCrest”), the Upper Tribunal (“UT”) has upheld the decision of the First-tier Tribunal (“FTT”) regarding the United Kingdom (“UK”) salaried...more

Cadwalader, Wickersham & Taft LLP

A Veterans Day Salute November 2022 | Issue No. 200 - The Jersey LLC Has Arrived

On 1 September 2022, the Limited Liability Companies (Jersey) Law 2018 (“LLC Law”) came into force, allowing limited liability companies (“LLCs”) to be established in Jersey. Jersey has introduced the LLC to attract U.S....more

Bracewell LLP

Changes to the Dubai International Financial Centre's ("DIFC") Legal and Regulatory Framework relating to DIFC registered...

Bracewell LLP on

His Highness Sheikh Mohammed bin Rashid Al Maktoum, in his capacity as president of the DIFC, vice president and prime minister of the United Arab Emirates (“UAE”) and Ruler of Dubai, has recently enacted a new set of laws...more

Perkins Coie

Blockchain Week in Review - July 2018

Perkins Coie on

The following update is on our Fintech Legal Report: FINRA Issues a Regulatory Notice for Firms to Let FINRA Know About Digital Asset Activities - U.S. Developments - Regulatory Updates - Vermont Enacts...more

Proskauer Rose LLP

Regulation Round Up - May 2018

Proskauer Rose LLP on

30 April - BEIS published a consultation paper seeking views on proposals to reform the laws relating to all UK limited partnerships. The key proposals are: - a requirement for all presenters to be registered with an...more

King & Spalding

A Guide to UK Tax on Commercial Real Estate: Non-Residents

King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

Goodwin

HMRC publishes responses to the consultation on Partnership taxation

Goodwin on

The result of the HM Revenue & Custom's consultation on UK partnership taxation was released on 20 March, this is important for both fund partnerships and fund managers structured as LLPs which file UK tax returns. Although...more

Pillsbury Winthrop Shaw Pittman LLP

Payment Practices and Performance Reporting - New UK rules aimed at tackling late payment of suppliers and vendors will require...

Under Section 3 of the Small Business, Enterprise and Employment Act 2015 (SBEEA 2015), the Secretary of State has the power, by regulations, to require certain companies to publish information about their payment practices...more

BCLP

Reverse Cross Border Merger Could Become Popular as UK Companies Restructure in Advance of Brexit

BCLP on

Reverse cross border mergers could become a popular device for UK companies seeking to maintain and preserve “passporting” or other EU rights. The mechanism of a reverse cross-border merger (in this context whereby a UK...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Cooley LLP

Alert: United Kingdom; New Beneficial Owner Disclosure Requirements; The PSC Register

Cooley LLP on

New UK laws, which came into force on April 6th, impose an obligation publicly to disclose the ultimate beneficial owners or controllers who have "significant control" over UK incorporated companies. The UK is the first...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

Pillsbury Winthrop Shaw Pittman LLP

UK Companies Must Disclose Beneficial Owners

From April 2016, UK companies will be required to maintain a publicly available register of people who have “significant control” over them. This new register is part of a wider movement to increase transparency around who...more

Latham & Watkins LLP

HMRC Responds to Landmark Case on UK Tax Treatment of Delaware LLCs

Latham & Watkins LLP on

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the UK Supreme Court’s decision in the landmark double taxation case of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

Dechert LLP

UK tax treatment of US LLC: HMRC’s practice following Anson

Dechert LLP on

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

Morgan Lewis

Recent UK Court Decision on UK Tax Treatment of US LLCs

Morgan Lewis on

HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners. Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

Latham & Watkins LLP

UK Supreme Court Forces HMRC to Rethink its Tax Treatment of Delaware LLCs

Latham & Watkins LLP on

Supreme Court rules in favour of taxpayer in landmark case regarding UK tax treatment of Delaware LLCs. On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her...more

Locke Lord LLP

UK Supreme Court Decision in Anson v. HMRC Reverses Established Tax Treatment of US LLCs

Locke Lord LLP on

In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more

Dechert LLP

Taxpayer wins landmark decision regarding the UK tax treatment of US LLCs

Dechert LLP on

Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more

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