Robert Langston (Saffery Champness) answers a query on the best structure from a tax perspective for a UK resident and member of a US LLC which carries on a trade in the US.
Question
I am UK resident and UK domiciled and I am a member in a US LLC which carries on a trade in the US. Is this the best structure from a tax perspective? If not can it be converted into a better structure?
Answer
Current structure
A limited liability company (LLC) is a common business structure in the US. It is flexible to manage but it does create some tax issues for non-US members.
By default an LLC is treated as ‘transparent’ for US tax...
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Robert Langston (Saffery Champness) answers a query on the best structure from a tax perspective for a UK resident and member of a US LLC which carries on a trade in the US.
Question
I am UK resident and UK domiciled and I am a member in a US LLC which carries on a trade in the US. Is this the best structure from a tax perspective? If not can it be converted into a better structure?
Answer
Current structure
A limited liability company (LLC) is a common business structure in the US. It is flexible to manage but it does create some tax issues for non-US members.
By default an LLC is treated as ‘transparent’ for US tax...
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:
