Taxpayer wins landmark LLC case
The Supreme Court has allowed the taxpayer's appeal in Anson (formerly Swift) v HMRC, which has been something of a long-running saga.
Originally heard in the First-tier Tribunal in 2010, the case concerns the UK tax treatment of Mr Anson, an individual member of a Delaware limited liability company (LLC). LLCs are a typically treated as 'transparent' for US tax purposes, whereas HMRC's long-standing view is that they should be regarded as 'opaque' for UK tax purposes.
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