The Resource Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?

Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?

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Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?
Title
Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?
Creator
Subject
Language
eng
Summary
This article looks behind the expert evidence on which the Supreme Court's decision in Anson v HMRC rested to explore whether, and if so on what basis, a Delaware limited liability company (LLC) can constitute a "body corporate" as well as considering, as an afterword, whether a foreign law partnership can be a "body corporate". In light of Brexit and the Government's quest to ensure that the UK is "open for business", improvements are proposed to HMRC's guidance on entity classification so as to, first, recognise more properly than was done in Revenue and Customs Brief 15 (2015) the Supreme Court's decision in Anson and, secondly, achieve not only simplification and modernisation by reducing the number of factors relevant for classification purposes but also greater clarity and certainty of outcome
Citation source
In: British tax review. - London. - (2016), no. 4 ; p. 466-489
http://library.link/vocab/creatorName
Montagu, G
Language note
English
http://library.link/vocab/subjectName
  • case law
  • entity classification
  • Brexit
  • tax credit
  • Delaware corporation
  • limited liability company
  • double non-taxation
  • foreign company
Label
Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?
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Publication
Label
Anson and entity classification revisited in light of Brexit : can an LLC constitute a "body corporate"?
Publication

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