International Tax IssuesAnswered

Do I owe Australian CGT if I sell my U.S. LLC membership interest?

E4
emma_4aa0new member
February 7, 2023 987 views 1 answer
australiaCGTcapital gainsLLC salemembership interestFIRPTA

I've been running my U.S. LLC for three years and I'm considering selling a 50% membership interest to a business partner. The LLC has appreciated significantly in value. Will Australia tax the capital gain on this sale? What about the U.S.? The LLC is not a real property holding company — its value is mainly in software IP and client contracts.

Related Questions

InternationalAnsweredFeatured

I'm from Australia — how does my U.S. LLC get taxed?

I'm an Australian citizen and tax resident in Sydney. I set up a Wyoming LLC for my SaaS business targeting U.S. customers. All development and operations happen from Australia. What are my U.S. and A...

LC
liam_c990·Apr 25, 2022
2,4561
InternationalAnswered

HMRC is treating my U.S. LLC as a company — how do I fix this double taxation?

I've been filing my LLC income as self-employment on my UK Self Assessment for two years. HMRC opened an inquiry and is now saying my Wyoming LLC should be treated as a foreign company subject to corp...

SD
sophie_ddbd·Nov 24, 2022
1,4871
InternationalAnswered

How do treaty tie-breaker rules work if I'm considered a tax resident of both the U.S. and my home country?

I'm a Canadian citizen who has been working in the U.S. for 3 years on a TN visa. I own an LLC in Delaware. Canada considers me a tax resident because I maintain a home in Toronto and my wife and kids...

DC
david_ca_f192·Sep 29, 2022
1,8471
InternationalAnswered

I filed Form 2350 expecting to qualify for the FEIE, but my travel pattern changed and now I may fail the test. What happens next?

I am from Australia and spent most of 2025 and 2026 moving between Singapore, Sydney, and California while running my U.S. LLC. I filed Form 2350 because I expected to meet the physical presence test ...

N3
naomi_3c12·Feb 7, 2026
1,8131
InternationalAnswered

My father was a non-resident alien who owned U.S. real estate. Do we need to file Form 706-NA?

My father recently passed away. He was a citizen of Mexico and never lived in the U.S., but he owned a vacation condo in Texas worth about $400,000. He also had a U.S. brokerage account with about $15...

C2
carlos_2831·Jun 30, 2023
1,3451
InternationalAnswered

Do I owe French social charges (cotisations sociales) on my U.S. LLC income?

My French accountant says I may owe social charges on my LLC income in addition to income tax. The cotisations sociales for self-employed workers in France can be 30-45% on top of income tax. If the L...

M8
marie_8a9a·Jul 2, 2022
1,3451
InternationalAnswered

Do Indonesia's CFC rules apply to my U.S. LLC?

My Indonesian tax consultant says my U.S. LLC might be subject to Indonesia's deemed dividend rules because it pays no U.S. tax. He says the DJP can treat undistributed LLC profits as if they were dis...

D7
dewi_78ed·Dec 13, 2019
8761
InternationalAnswered

I'm from Israel — how does my U.S. LLC get taxed?

I'm an Israeli citizen and tax resident in Tel Aviv. I formed a Delaware LLC for my cybersecurity consulting business. I work from Israel serving U.S. clients. What are my IRS and Israel Tax Authority...

N1
noam_1128·Jan 10, 2021
1,5671
InternationalAnswered

How does Italian CFC legislation apply to my U.S. disregarded LLC?

My Italian commercialista says my U.S. LLC triggers Italy's CFC rules because it pays no U.S. tax. He says I have to pay IRPEF on the LLC's entire income even though I left most profits in the U.S. ba...

G7
giulia_759f·Jun 25, 2021
9871
InternationalAnswered

I'm from Italy — how does my U.S. LLC get taxed?

I'm an Italian citizen living in Milan. I formed a Delaware LLC for my design consulting business serving international fashion brands. I work entirely from Italy. What are my IRS and Agenzia delle En...

M7
marco_7385·Dec 21, 2024
1,5671

Have a similar question?

ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.

Become a Member — $9.99/mo

Disclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.

Watch the walkthroughs