.png)
.png)
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...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
