Allan Cinnamon (Cintax the Word Ltd) provides your monthly update.
Anson: the treaty aspects
By now it is well known that the Supreme Court in Anson v HMRC [2015] UKSC 44 (reported in Tax Journal 7 July 2015) has ruled that the profits of a US LLC accrued to its members as they arose reversing HMRC’s assertion that the LLC was opaque.
Having established that there remained the question of whether Mr Anson as a UK resident member of the LLC was entitled to double tax relief for the US tax that he had paid on his share of the LLC’s profits. Article 23.2(a) of the 1975 treaty provided for relief from the US federal tax specified in...
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Allan Cinnamon (Cintax the Word Ltd) provides your monthly update.
Anson: the treaty aspects
By now it is well known that the Supreme Court in Anson v HMRC [2015] UKSC 44 (reported in Tax Journal 7 July 2015) has ruled that the profits of a US LLC accrued to its members as they arose reversing HMRC’s assertion that the LLC was opaque.
Having established that there remained the question of whether Mr Anson as a UK resident member of the LLC was entitled to double tax relief for the US tax that he had paid on his share of the LLC’s profits. Article 23.2(a) of the 1975 treaty provided for relief from the US federal tax specified in...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
that the Supreme Court in Anson v HMRC [2015] UKSC 44 (reported in Tax Journal 7 July 2015) has ruled that the profits of a US LLC accrued to its members as they arose reversing HMRC’s assertion that the LLC was opaque.
