The Upper Tribunal has decided (upholding the First-tier Tribunal's decision) that transactions involving a Delaware LLC had no tax avoidance purpose. Therefore, the "transfer of assets abroad" rules in what was section 739 of the Income and Corporation Taxes Act 1988 did not apply to allow the taxpayer to claim double tax relief on his LLC profit share. (HMRC v Anson [2012] UKUT 59 (TCC).)