Law360, New York ( July 6, 2015, 5:42 PM EDT) -- In an outcome that has surprised many and challenges long-standing HM Revenue & Customs practice, the U.K. Supreme Court has ruled that a Delaware limited liability company was "transparent" for U.K. income tax purposes, so that a U.K. resident member was taxable on the profits of the LLC as they arose, and not on the distribution of those profits (Anson v. HMRC [2015] UKSC 44, formerly Swift v HMRC)....
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