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29 September 2015
HMRC brief published on Anson.
HMRC have concluded that the Supreme Court’s decision in George Anson v CRC [2015] STC 1777 is specific to the facts found in the case.
As a result when US limited liability companies have been treated as companies within a group structure HMRC will continue to treat them as companies. When a US limited liability company has been treated as carrying on a trade or business HMRC will continue to treat it in the same way.
HMRC say their approach to determining whether a US limited liability company should be regarded as issuing share capital will not change. Individuals claiming double tax relief and relying on the Anson decision will be considered on a case-by-case basis.
In Anson in accordance with their practice HMRC said the taxpayer received...
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