UK Investors in US LLCs Exposed to Double Taxation – Is This the End of the Story?
Journal
Country
United Kingdom
Published Date
Issue
European Taxation 2013 (Volume 53), No. 6
Document
This note addresses the UK position on double taxation relief in situations involving hybrid entities, as recently illustrated by the Court of Appeal decision in Anson (2013). The implications of the case are discussed from an international tax perspective.