Rachel Reeves promises consultation on UK taxation of US LLCs

The FT’s report that Rachel Reeves has instructed the UK Treasury to examine the tax rules that can result in double taxation (see Anson article) for UK resident members of US LLCs is welcome. We look forward to the promised consultation.

On the wider picture of making UK plc attractive to wealthy individuals and families, who are internationally mobile nowadays, we can hope that this welcome signal prompts:

  • The UK Treasury to revisit the UK’s inheritance tax regime as well. For example, for those US citizens that Rachel Reeves wants to attract to the UK, the difference between the tax-free allowance for individuals in the US (a $15m lifetime exemption that increases annually for inflation) and the UK (£325,000) is material, even if planning (see FLP article) can bridge the gap.
  • The UK Government to streamline the visa rules (see more about immigration options) for wealthy individuals and families who can invest in the UK, as well as entrepreneurs and talented individuals who help drive growth.

She will promise that the Treasury will revisit tax rules which currently mean that people who receive income from a US limited liability company and move to the UK can face being taxed on both sides of the Atlantic. A consultation on the rules will be launched in due course.

https://www.ft.com/content/35d396e7-5590-4c65-9989-0c136e937fd7?accessToken=zwAAAZ2Ql-A_kc8105bnVZBMZdOZiQwTbpN_1w.MEQCIFYORv4gOaDblvDD22zQ3LbnzGNqrYLuZ89gR5XH76bcAiB6BWdkk666DRaVrlkpvxdvCSi4_M1q6NwU4zK3-5ZKmg&sharetype=gift&token=aa925671-db2c-4d47-b477-f8180296d3aa&syn-25a6b1a6=1
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