I am UK resident and UK domiciled and I am a member in a US LLC which carries on a trade in the US. Is this the best structure from a tax perspective? If not can it be converted into a better structure?
Answer
Current structure
A limited liability company (LLC) is a common business structure in the US. It is flexible to manage but it does create some tax issues for non-US members.
By default an LLC is treated as ‘transparent’ for US tax purposes similar to a partnership in the UK. This means that the members are taxed on the profits of the LLC (and must file US tax returns) rather than the LLC...
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I am UK resident and UK domiciled and I am a member in a US LLC which carries on a trade in the US. Is this the best structure from a tax perspective? If not can it be converted into a better structure?
Answer
Current structure
A limited liability company (LLC) is a common business structure in the US. It is flexible to manage but it does create some tax issues for non-US members.
By default an LLC is treated as ‘transparent’ for US tax purposes similar to a partnership in the UK. This means that the members are taxed on the profits of the LLC (and must file US tax returns) rather than the LLC...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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