UK HMRC Consults on Tax Treatment of Individual Members of US LLCs and Other Reverse Hybrids

UK HMRC has launched a public consultation on the reform of the taxation of UK resident individual members of reverse hybrid entities, such as U.S. limited liability companies (LLCs). Reverse hybrids are entities that are treated as transparent in their jurisdiction of establishment but as opaque for UK tax purposes. Under the current position, HMRC generally treats most U.S. LLCs as opaque for UK tax purposes, while U.S. LLCs are generally taxed transparently in the United States unless a ch…