UK Investors in US LLCs Exposed to Double Taxation – Is This the End of the Story?

Journal
Popa, O.
United Kingdom
European Taxation 2013 (Volume 53), No. 6
FormatPDF
EUR
45
| USD
50 (VAT excl.)

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.