[2010] UKFTT 88 (TC)

[The appeal against this decision is reported at [2011] BTC 1,841 and [2012] BTC 1,552.]

Judge John F Avery Jones CBE (Chairman), Ian Menzies-Conacher FCA CTA (Fellow) ACIB

Decision released 22 February 2010

Double taxation relief – individual investor in Delaware LLC – whether entitled to the profits as they arise – yes – accordingly the appellant is entitled to credit for US tax paid by him, the LLC being transparent for US tax purposes – if wrong, the LLC is not treated as transparent by s. 739 on the basis that s. 741 is satisfied – if wrong R & C Commrs were entitled to make discovery assessments

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