Supporting a property fund with complex cross-border tax exposure
A £12 million US investment presented a major opportunity for our UK-based client, but its cross-border nature created a complex tax challenge.
We worked with UK and US advisers to design a structure that addressed the potential US tax exposure while keeping the investment transparent, compliant and tax-efficient.
The result was a robust structure that gave the client the confidence to proceed with a significant international investment, without unwanted immediate US tax implications.
The challenge
A UK-based client was ready to invest £12 million into a US venture, a major opportunity with one big challenge: complex cross-border tax exposure.
The client didn’t have a direct relationship with the US company and wanted to avoid any unwanted US tax implications.
They needed a structure that would let them invest with confidence: simple, compliant, and tax-efficient on both sides of the Atlantic.
What we did
We stepped in to design and deliver the right structure from the ground up. Working with UK/US advisers, our team advised on the creation of a US Limited Liability Company (LLC) – the American equivalent of a UK LLP – and paired it with a General Partner / Limited Partner (GPLP) structure in the UK.
This combination ensured that:
- US tax liabilities didn’t roll up to the UK
- The investment remained transparent and compliant
- The client could invest without triggering unwanted US tax obligations
In short, we turned a potentially complex international investment into a seamless, efficient structure that worked perfectly for our client’s needs.
The result
The result was exactly what the client wanted:
- A £12 million investment made tax-efficient
- No immediate US tax exposure
- Peace of mind that the structure was sound, compliant, and built to last
We helped our client go from hesitation to confident investment – proving that with the right structure, cross-border doesn’t have to mean complicated.
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