Anson v. HMRC

Holding

A Delaware LLC's profits could be sourced as Anson's own income for UK tax purposes given the partnership-like treatment under Delaware law and the LLC agreement.

Facts

Anson received distributions from a Delaware LLC of which he was a member. He claimed UK foreign-tax-credit relief for U.S. tax on his share of LLC profits.

Reasoning

Lord Reed held that the LLC profits arose directly to Anson under Delaware law in a manner equivalent to a partnership, allowing UK FTC relief. The decision is significant for UK tax treatment of foreign hybrid entities.