bostonwilly

Hi all,

I've been granted some common shares in the LLC I work for. I'm currently UK resident and will be USA resident later this year. I believe I should file a 83(b) election and apply for an ITIN at the same time (I don't have one yet). Does that sound right?

As far as the UK goes, I believe that these are not an approved UK employee share scheme and therefore I'll be taxed on the gain from now until they are free of restrictions, pro-rata with the time I spend in the UK until then, which should only be a few months out of several years. Is anyone aware of anything I could be doing regarding the UK side of this? I'm not really looking to spend ages avoiding tax, just want to make sure I'm right by the rules.

Cheers

tht

No.

If it’s an LLC you don’t have “shares” that would be a S or C corporation. LLC have members, with the partnership agreement allocating the terms.

bostonwilly

Is that a "no" I got the nomenclature wrong or a "no" there is nothing that should/could be done?

tht

no idea on the UK aspect, if it’s an LLC it is a private / unlisted company, for a multi member LLC I think you file your “distributive share” income and expenses (even if retained by the LLC and not distributed) as a schedule E to your 1040. I doubt you would need a tax ID until 2023 to file your 2022 tax’s if you have not moved here, or did you become a member of the LLC before 1 Jan 2022?