There is a certain policy logic for HMRC’s revised guidance which doubles down on its view that US LLCs should generally be treated as ‘opaque’ (often the desired treatment from a UK corporation tax perspective); HMRC’s position enables it to adopt a more uniform approach that, in practice, does not require it to review the […]
US LLCs in the UK? Let’s Talk about Anson v HMRC Read More »
The OECD maintains and regularly updates this list of frequently asked questions (FAQs) on the application of the Common Reporting Standard (CRS). These FAQs were received from business and government delegates. The answers to such questions provide further precisions on the CRS and help to ensure consistency in implementation. More information on the CRS
CRS-related Frequently Asked Questions Read More »
The definition of nominee is pretty broad. Usually any nominee arrangement wouldn’t work. CRS Commentary page 200… Paragraph E – Miscellaneous Subparagraph E(1) – Account Holder Subparagraph E(1) defines the term “Account Holder” as the person listed or identified as the holder of a Financial Account by the Financial Institution that maintains the account.
Can I use Nominees to avoid CRS and CARF? Read More »
