Open consultation

UK resident individual members of LLCs and other reverse hybrids  

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

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 closes at
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 US LLCs

HTML

Ways to respond

Email to:

entityclassificationmailbox@hmrc.gov.uk

Write to:

Base Protection Policy Team
HM Revenue and Customs
Floor 7, 3 Arena Central
Birmingham
B1 2AX

Published 10 June 2026