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Where Taxpayers and Advisers Meet

US LLC corporate partner in UK

Tom7000
Posts: 68
Joined: Wed Aug 06, 2008 3:30 pm

US LLC corporate partner in UK

Postby Tom7000 » Wed Jan 09, 2019 5:50 pm

The US LLC has a UK corporate partner. The LLCis taxed in US as a partnership - so no tax

The UK treats the LLC like a company not a partnership and only taxes uk ‘’partners’ when the profits are distributed.

What we need to know is

1. What is the definition of distributed ie
a. when the profits are allocated to the partners in the US accounts or
b. when the UK partner receives a cash remittance

2. When we know the answer to this then we need to know the tax treatment of these funds, is it treated

a. as partnership income and taxed in the UK or
b. Dividend income and its exempt CT for a corporate partner.

So two exam A or B questions – easy 😊

Puzzled of Farnborough

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