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 corporation tax, not as transparent. This means my income gets taxed once at the LLC level (corporation tax) and again when I take distributions (dividend tax). How do I argue for transparent treatment? Has anyone dealt with this?
Related Questions
I'm from Canada — how does my U.S. LLC get taxed?
I'm a Canadian citizen and resident in Toronto. I formed a Delaware LLC for my software development freelancing business with U.S. clients. I do all work from Canada. What are my tax obligations in bo...
How does the German Finanzamt treat U.S. disregarded entities?
My Steuerberater says Germany will tax my U.S. LLC as if it were a GmbH. But my U.S. CPA says the LLC is disregarded and I do not owe U.S. corporate tax. This mismatch means I am paying German corpora...
I'm from the UK — how does my U.S. LLC get taxed?
I'm a UK citizen and tax resident living in London. I set up a Wyoming LLC for my online consulting business. I work entirely from the UK and bill U.S. clients through the LLC. What are my U.S. and UK...
Canada taxed income that the U.S. seems to treat as U.S.-source. Is treaty re-sourcing the reason people use a separate Form 1116 basket?
I am a Canadian founder who became a U.S. resident but still has compensation items that Canada continues to tax. My preparer mentioned 'certain income re-sourced by treaty' and said it may require a ...
How does the India-U.S. DTAA apply to my disregarded LLC income?
I own a U.S. LLC that earns both consulting fees and some interest income from a U.S. bank account. I understand the India-U.S. DTAA should prevent double taxation, but I'm confused about how it works...
What are the anti-inversion rules under IRC 7874 and how do they affect foreign-owned structures?
I've been reading about corporate inversions — companies moving their tax domicile overseas to reduce U.S. taxes. We are a foreign company considering acquiring a U.S. target, and our advisors warned ...
Do I owe Australian CGT if I sell my U.S. LLC membership interest?
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 capita...
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...
How does the Israel Tax Authority treat U.S. disregarded entities?
I've been told that Israel may or may not treat my U.S. LLC as transparent. If it treats the LLC as a company, I could face CFC issues. If it treats it as transparent, the income is mine directly. How...
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...
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/moDisclaimer: 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.
