HMRC consultation on US LLCs

HMRC has published a consultation on proposed changes to the UK tax treatment of UK individual members of US LLCs and other reverse hybrid entities

16 June 2026

Event

HMRC has published a consultation on proposed changes to the UK tax treatment of UK individual members of US LLCs and other reverse hybrid entities. The consultation proposes the introduction of legislation to ensure that such individuals are not prevented from claiming double tax relief on profits distributed by US LLCs by treating UK individuals as, essentially, partners in such entities (even though HMRC would normally classify them as opaque for UK tax purposes).

Join us at 2pm (BST) on Tuesday 16 June for an online webinar where we will explain the issues faced by UK individual members of US LLCs and look at these proposals in more detail.

Register below.

Enquiries
Darren Oswick
darren.oswick@simmons-simmons.com

Martin Shah
martin.shah@simmons-simmons.com