Delaware limited liability companies (LLCs) are regularly seen in international corporate groups.
Their treatment is flexible for US tax purposes, as by default they are treated in the same way as partnerships, although they are able to elect to be treated as a corporation for US tax purposes. No such elective regime exists in the UK, and the tax treatment of them and their members will turn on whether or not the LLC is opaque or transparent for UK tax purposes. Until now HMRC’s practice (which was widely accepted as being correct) has been that they should normally be treated as opaque.