News & Analysis as of

Limited Liability Company (LLC) Tax Treaty

Rivkin Radler LLP

Moving to the U.S.? Have You Planned for the Estate and Gift Taxes?

Rivkin Radler LLP on

It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more

Foodman CPAs & Advisors

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are...more

Arnall Golden Gregory LLP

LLCs May Be Right Unless They’re Wrong

As I’ve posted before, I usually advise non-US companies to form a corporation when expanding to the United States. Every now and then, I get some pushback because the non-US company has heard about ‘limited liability...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

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

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