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- Title
Recent Judicial Developments Affecting Investments Into and Out of the United Kingdom.
- Authors
McGowan, Michael; Thomson, Andrew
- Abstract
This article reports on two sets of judicial developments in the United Kingdom of interest to U.S. companies and investors considering investing in them. First, the authors discuss the U.K. Upper Tribunal's reversal of a lower court decision dealing with the U.K. classification for tax purposes of a Delaware limited liability company (LLC), which creates the potential for double taxation and thus might dissuade a taxpayer considering investment in such an LLC. Second, the authors look at a U.K. Supreme Court decision on the concept of residence for U.K. tax purposes. As the global economy expands, and more and more individuals work abroad, the U.K. residency question is of importance to "expat" employees and their employers, in the U.S. and elsewhere.
- Subjects
UNITED Kingdom; INVESTMENTS; ACTIONS &; defenses (Administrative law); DOUBLE tax agreements; LIMITED liability partnership; INHERITANCE &; transfer tax
- Publication
Journal of Taxation of Investments, 2012, Vol 29, Issue 3, p69
- ISSN
0747-9115
- Publication type
Article