Closed consultation

UK resident individual members of LLCs and other reverse hybrids  

• From: HM Revenue & Customs
• Published: 10 June 2026

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Summary

Consultation on a new measure to mitigate double taxation for individuals investing in certain overseas entities (including US Limited Liability Companies (LLCs). 

This consultation ran from
9:30am on 10 June 2026 to 11:59am on 31 July 2026

Consultation description

This consultation details the current tax position for UK resident individuals who are members of reverse hybrids such as US LLCs and identifies where unintentionally high effective tax rates may arise for these individuals, due to entity classification mismatches between the UK and other jurisdictions that results in double taxation. It sets out proposed solutions and invites feedback from stakeholders.

Documents

Consultation on reform to taxation of UK-resident members of LLCs and other reverse hybrids

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Published 10 June 2026