Key takeaways

• The UK Supreme Court has passed down its judgment in the controversial case of Anson v HMRC regarding the status of a Delaware LLC in UK tax law.
• In contrast to HMRC’s established practice, the Supreme Court held that a Delaware LLC was transparent for UK income tax purposes.
• The case is a victory for the taxpayer, who is now able to claim double tax relief for U.S. state and federal tax against his UK income tax liability, but creates uncertainty for future tax planning.