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The implications of the Anson decision for UK taxpayers who have income from shares in a US limited liability company
KEY POINTS
- Was the Delaware LLC like a UK limited company or a UK limited liability partnership?
- Nature of the income received by the taxpayer.
- Opportunities exist for shareholders in Delaware LLCs to obtain double tax relief.
- Corporation tax may be due on income belonging to corporate UK taxpayers.
When talking to clients about cross-border taxation I begin with the hypothesis that most people would agree that taxing the same money twice is not just.
When dealing with a client who could be tax resident in more than one jurisdiction this principle generally stands up to scrutiny. This is due to the UK’s extensive network of double taxation agreements (DTAs) coupled with the credit given by UK law called unilateral relief.
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