4 minute read.
Liz Zitzow looks at the case of Anson v HMRC on the subject of US/UK
It’s been a few years on since Anson v HMRC back on 1 July 2015. For those who don’t know or recall that case, here’s what happened: Mr Anson owned a limited liability company (LLC) which elected like most LLCs to treat itself as a partnership in the US.
The UK doesn’t recognise this and it results in double taxation despite our lovely US/UK income tax treaty. The tax paid by the individual on his partnership income in the US is not a deductible tax for the corporation’s tax return with HMRC and it’s not useful as a credit against his personal tax on the dividends since it’s for work, not dividends.