International Tax IssuesAnswered

Treas. Reg. 1.894-1(d) — when does the LLC owner claim the US treaty vs the LLC itself?

MG
marcus_gb_ad11new member
May 15, 2026 826 views 1 answer
treas reg 1.894-1(d)treaty claimdisregarded entityowner-level derivationfiscally transparent

I own a single-member US LLC (disregarded for US tax purposes). I'm a UK resident. A US payer asked which W-8 form to use, and someone told me the LLC claims the US-UK treaty in its own name. Someone else said the foreign owner claims it. Which is right, and what's the underlying rule?

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