ARTICLE · 09 JULY 2015

Weekly Tax Update - July 6, 2015

Smith & Williamson

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The Finance Bill to be introduced by the Summer Budget on 8 July will be published on 15 July.

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1 GENERAL NEWS

1.1 Publication of Finance Bill

The Finance Bill to be introduced by the Summer Budget on 8 July will be published on 15 July.

www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Commons/2015-06-30/HCWS72

1.2 Supreme Court – Anson and UK tax treatment of income from US LLCs

The Supreme Court has overturned the Court of Appeal decision in Anson, with the result that Mr Anson will be entitled to double tax relief on his share of a US LLC's (Limited Liability Company) profits for the UK tax years running from 6 April 1997 to 5 April 2004. In the US, LLC partners are effectively treated as receiving taxed partnership profits (ie transparent for tax purposes), whereas in the UK the LLC is viewed as being opaque so that LLC members are treated as receiving dividend income from the LLC. Up to now double tax relief for UK individuals in receipt of US LLC profits already taxed in the US has been denied as

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