A recent Tribunal decided that the profits of a particular US LLC belonged to the individual members as they arose and that the UK member should be taxed accordingly.

Since the member was thereby taxed on the same income in both countries, he was entitled to double taxation relief for US tax paid on his share of the LLC's profits.

HMRC has appealed the decision and intends, for the time being, to continue with its current general practices in relation to US LLCs.

Details of the background to the case and the decision are reproduced here.