HMRC wins LLC transparency decision

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

HMRC wins LLC transparency decision

August 10 2011

The UK Upper Tier Tribunal on August 3 reversed a controversial lower court opinion and found that a Delaware limited liability company (LLC) is not transparent for UK tax purposes.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesUnited KingdomEuropeJurisdictions
more across site & shared bottom lb ros

More from across our site

Direct Tax
France business handshake
French Finance Act 2025: Major tax reform for management packages
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
Bruno Knadjian , July 03 2025
Transfer Pricing
Grocery store
‘TP litigation here to stay’: experts dissect South Africa ruling
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Sam Sholli, July 02 2025
Indirect Tax
TP document - compliance.jpg
This month in indirect tax: compliance the top challenge for indirect tax, Thomson Reuters finds
Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales
Sam Sholli, July 02 2025
Direct Tax
Artificial intelligence
AI in tax: what’s the direction of travel?
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
Russell Gammon, July 01 2025
Direct Tax
Lewin Higgins-Green -- FTI Consulting.jpg
Five minutes with…Lewin Higgins-Green, FTI Consulting
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
July 01 2025
Direct Tax
US Canada trade
Canada to scrap DST in bid to resume US trade negotiations
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
Sam Sholli, June 30 2025
Direct Tax
Parliament House Canberra
PwC Australia’s government contract ban should be extended, senators say
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Tom Ravlic, June 30 2025
Transfer Pricing
Global digital
DSTs as digital infrastructure: the tax challenges of emerging markets
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Neil Kelley, June 27 2025
Direct Tax
scott bessent.jpg
Pillar two taxes won’t apply to US companies: US Treasury secretary
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
Sam Sholli, June 27 2025
Direct Tax
PwC.jfif
This week in tax: PwC Australia’s tax function generates A$475m amid tumbling 2024 profits
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Sam Sholli, June 27 2025
Gift this article