What is the view of HMRC on the recent Swift case regarding UK tax treatment of a US Limited Liability Company (LLC)?
HMRC has appealed the decision in the recent tribunal case Swift v HMRC TC 00399 and intends, for the time being, to continue with its current general practices in relation to US LLCs. If, however, any member of a US LLC feels that the UK treatment of a particular LLC should be reviewed in the light of the decision of the Tribunal, they should write to Stan Surgin, Business International, Yorke House, Castle Meadow Road, Nottingham, NG2 1BG setting out fully why they believe that to be the case. Click for more information.
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