UK resident individual members of LLCs and other reverse hybrids
Consultation on a new measure to mitigate double taxation for individuals investing in certain overseas entities (including US Limited Liability Companies (LLCs).
Detail
This consultation details the current tax position for UK resident individuals who are members of reverse hybrids such as US LLCs and identifies where unintentionally high effective tax rates may arise for these individuals, due to entity classification mismatches between the UK and other jurisdictions that results in double taxation. It sets out proposed solutions and invites feedback from stakeholders.
Documents