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2. www.pkf-l.com › insights › tax-talk-doing-businessTax Talk: Doing business in the US through an LLC – UK tax ...

   www.pkf-l.com › insights › tax-talk-doing-business

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   Dec 16, 2021 · UK companies and resident individuals conducting business in the US often do so through a US limited liability company (LLC). But there are uncertainties for UK taxpayers. Jonathon Collins and Tom Golding explain.

3. www.buzzacott.co.uk › insights › tax-considerationsTax considerations of US (LLCs) for UK residents - Buzzacott

   www.buzzacott.co.uk › insights › tax-considerations

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   Jun 22, 2022 · If you’re a US citizen who’s already UK resident or planning to move to the UK, you should be aware of the mismatch between the UK and the US when it comes to LLCs. In these case studies we show potential solutions for investors or business owners to mitigate the tax implications.

4. www.thetaxadviser.com › issues › 2012U.S. LLCs for U.K. Tax Purposes - The Tax Adviser

   www.thetaxadviser.com › issues › 2012

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   U.S. LLCs for U.K. Tax Purposes. By Rob Whittall, CPA. September 30, 2012. TOPICS. U.S. limited liability companies (LLCs) have become the preferred business entity in many situations because their members get the best of both worlds: legal liability protection while being taxed in the United States as a partnership.

5. brighttax.com › blog › us-uk-tax-treatyUS-UK Tax Treaty Rules: What Expats Must Know

   brighttax.com › blog › us-uk-tax-treaty

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   Feb 21, 2024 · If you’re an American living in the UK, the US-UK treaty can benefit you by: Capping the tax rates that the UK may levy on US-sourced dividends, interest, and royalties at 10%; Exempting lump-sum withdrawals from UK-based pensions from taxation; Making certain US-sourced payments (e.g., pensions/retirement accounts, Social Security, annuities ...

6. www.hrblock.com › the-u-k-u-s-tax-treaty-explainedUnderstanding the U.S./U.K. Tax Treaty | H&R Block®

   www.hrblock.com › the-u-k-u-s-tax-treaty-explained

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   Mar 4, 2024 · The U.S./U.K. tax treaty is one of them, and it protects U.S. expats in the U.K. from paying more than their fair share of U.S. taxes. Keep reading to find out more about the U.S./U.K. tax treaty below. Not sure about filing requirements for your U.S. expat taxes in the U.K.? We’re here to help. Get started now. File on my own. File with an advisor

7. People also ask

   Are UK companies taxable in the US?

   • UK companies and resident individuals conducting business in the US often do so through a US limited liability company (LLC). But there are uncertainties for UK taxpayers. Jonathon Collins and Tom Golding explain. An LLC is a common business form in the US and does provide some benefits. But mismatches can arise between US and UK tax treatments.

   Tax Talk: Doing business in the US through an LLC – UK tax pitfalls

   www.pkf-l.com/insights/tax-talk-doing-business-in-the-us-through-an-llc-uk-tax-pitfalls/

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   Are US LLCs taxed in the UK?

   • This issue is not only between the United Kingdom and United States. Many countries struggle with classifying U.S. LLCs’ profits under their own domestic tax statutes. From a U.K. perspective, a U.K. citizen and resident who invests in a U.S. LLC in his or her personal name is going to be subject to double taxation.

   U.S. LLCs for U.K. Tax Purposes - The Tax Adviser

   www.thetaxadviser.com/issues/2012/oct/witthal-banner12.html

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   Is a US LLC still an opaque ENTITY for UK tax purposes?

   • Unfortunately, while the Anson case would be useful here, HMRC has taken the view that the Anson decision was fact specific. HMRC has therefore maintained its general position that a US LLC is still an opaque entity for UK tax purposes. HMRC will consider whether an LLC meets the Anson criteria on a case-by-case basis.

   Tax considerations of US (LLCs) for UK residents - Buzzacott

   www.buzzacott.co.uk/insights/tax-considerations-of-us-limited-liability-companies-llcs-for-uk-residents

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   How does UK tax a UK member of an LLC?

   • Accordingly, the UK taxes a UK member of an LLC by reference to distributions of profits made by the LLC and not by reference to the income of the LLC as it arises. If tax is paid in the US on the profits of the LLC - and irrespective of by whom that tax is paid - the UK regards that tax as underlying tax.

   Double Taxation Relief Manual - GOV.UK

   www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt19853

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8. www.gov.uk › hmrc-internal-manuals › double-taxationDouble Taxation Relief Manual - GOV.UK

   www.gov.uk › hmrc-internal-manuals › double-taxation

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   US LLCs - relief for US tax {#} Relief for underlying tax will only be available to a UK company which has at least a 10% interest in the US LLC (see Article 24 (4) (b)). This is...