Langer on Practical International Tax Planning provides current knowledge and expert advice attorneys need to help clients capitalize on ripe tax havens and financial centers.
Stocked with case studies that illustrate sound planning approaches, this book enables you to:
Select the right territories for each client
Deploy the right instruments within each territory to eliminate, reduce, or defer taxes
Avoid planning missteps that trigger tax problems
Use local contacts to open doors to tax havens
Respond effectively to changing tax planning situations in specific havens and financial centers
Regularly updated, Langer on Practical International Tax Planning gives you the latest word on the legal, tax, business, financial, social, political, technological, geographical, and regional factors to consider when developing and implementing customized planning strategies for clients. It is an invaluable tool for tax and estate planners, tax attorneys, accountants, and sophisticated investors.
Publication Date: June 2019
Last Updated: November 2021
ISBN: 9781402430046
Number of Volumes: 2
Table of Abbreviations
PART 1: U.S. Tax Rules that Affect Overseas Transactions of U.S. Persons
PART 2: Why Tax Havens Exist
Chapter 1: The Growth of Excessive Taxation
Chapter 2: Jurisdictional Bases for Taxation
PART 3: The Basics of International Tax Planning
Chapter 3: Determining the Source of Income
Chapter 4: Determining the Situs of Assets (Intangibles)
Chapter 5: Foreign Tax Credits
Chapter 6: Foreign Currency Transactions
Chapter 7: Transfer Pricing and Advance Pricing Agreements; and Appendix 7A
Chapter 8: Working with Tax Treaties; and Appendices 8A-8B
Chapter 9: Treaty-Based Return Positions
Chapter 10: Limitations on Treaty Shopping
PART 4: Tax Planning for Individuals
Chapter 11: How U.S. Citizenship Is Acquired
Chapter 12: Tax-Motivated Loss of Citizenship
Chapter 13: Visas Permitting U.S. Residence
Chapter 14: Residence Status for Tax Purposes
Chapter 15: Domicile and Its Impact on Taxes
Chapter 16: Estate Planning for Nondomiciled Aliens
Chapter 17: Mixed Marriages Between Citizens and Aliens; and Appendices 17A-17B
Chapter 18: Tax Benefits for Citizens Working Abroad
Chapter 19: Investments Abroad
PART 5: Using Companies
Chapter 20: Characterization of Entities for Tax Purposes
Chapter 21: Using Limited Liability Companies
PART 6: Using Trusts
Chapter 22: Who Can Use Offshore Trusts
Chapter 23: Changing the Situs of a Trust
Chapter 24: Emergency Trusts and Asset-Protection Trusts
PART 7: Secrecy, Disclosure, and Information Exchange
Chapter 25: Disclosure Requirements
Chapter 26: Tax and Information Returns
Chapter 27: What Governments Do with Your Information
Chapter 28: Information Exchange Between Countries; and Appendices 28A-28C
Chapter 29: Mutual Administrative Assistance in Tax Matters; and Appendices 29A-29B
PART 8: Tax Planning for Inbound Investments
Chapter 30: Foreign Investment in Bank Deposits
Chapter 31: Foreign Investment in Stocks and Bonds
Chapter 32: Foreign Investment in Real Estate
Chapter 33: Branch Profits Tax on Foreign Corporations
Chapter 34: Choosing Among Corporations, Partnerships, and LLCs
Chapter 35: Deducting Interest Paid to Related Parties
Chapter 36: Inbound Transactions: Withholding and Reporting
PART 9: Tax Planning for Outbound Activities
Chapter 37: U.S. Taxation of Foreign Corporation Operations
Chapter 38: Controlled Foreign Corporations
Chapter 39: Foreign Personal Holding Companies (FPHCs)
Chapter 40: Passive Foreign Investment Companies (PFICs)
