TAX
LANGER ON PRACTICAL INTERNATIONAL TAX PLANNING Edward J . Smith ( Attorney at Law )
CONTENTS
VOLUME 1 PART I : U . S . TAX RULES THAT AFFECT OVERSEAS TRANSACTIONS OF U . S . PERSONS
PART I-A : WHY TAX HAVENS EXIST 1 The Growth of Excessive Taxation 2 Jurisdictional Bases for Taxation
PART I-B : THE BASICS OF INTERNATIONAL TAX PLANNING 3 Determining the Source of Income 4 Determining the Situs of Assets ( Intangibles ) 5 Foreign Tax Credits 6 Foreign Currency Transactions 7 Transfer Pricing and Advance Pricing
Agreements 8 Working with Tax Treaties 9 Treaty-Based Return Positions 10 Limitations on Treaty Shopping
PART I-C : TAX PLANNING FOR INDIVIDUALS |
11 |
How U . S . Citizenship Is Acquired |
12 |
Tax-Motivated Loss of Citizenship |
13 |
Visas Permitting U . S . Residence14 |
Residence Status for Tax Purposes |
15 |
Domicile and Its Impact on Taxes |
16 |
Estate Planning for Nondomiciled Aliens |
17 |
Mixed Marriages Between Citizens |
and Aliens |
18 |
Tax Benefits for Citizens Working Abroad |
19 |
Investments Abroad |
PART I-D : USING COMPANIES |
20 |
Characterization of Entities for Tax Purposes |
21 |
Using Limited Liability Companies |
PART I-E : USING TRUSTS |
22 |
Who Can Use Offshore Trusts |
23 |
Changing the Situs of a Trust |
24 |
Emergency Trusts and Asset-Protection Trusts |
VOLUME 2 PART I-F : SECRECY , DISCLOSURE , AND INFORMATION EXCHANGE 25 Disclosure Requirements 26 Tax and Information Returns 27 What Governments Do with Your Information 28 Information Exchange Between Countries 29 Mutual Administrative Assistance in
Tax Matters
Authored by a notable tax attorney with a global practice , this treatise offers a comprehensive resource for capitalizing on favorable tax havens and financial centers .
Global tax practitioners and their clients can access forms and checklists covering qualified domestic trusts , achieving QI status , and more . They will gain insights around selecting suitable territories for each client ’ s tax situation , territory-specific tax mitigation instruments , planning best practices , foreign tax credits , tax treaties and treaty shopping , asset situs analysis , and strategy adjustment approaches .
Stay abreast of ever-changing international tax planning best practices with PLI ’ s Upkeep Service .
2 looseleaf volumes , 1,414 pages , $ 806 , Item # 239302 , ISBN 978-1-4024-3004-6 , Updated annually or as needed
PART I-G : TAX PLANNING FOR INBOUND |
INVESTMENTS |
30 |
Foreign Investment in Bank Deposits |
31 |
Foreign Investment in Stocks and Bonds |
32 |
Foreign Investment in Real Estate |
33 |
Branch Profits Tax on Foreign Corporations |
34 |
Choosing Among Corporations , |
Partnerships , and LLCs |
35 |
Deducting Interest Paid to Related Parties |
36 |
Inbound Transactions : Withholding and |
Reporting |
PART I-H : TAX PLANNING FOR OUTBOUND ACTIVITIES 37 U . S . Taxation of Foreign Corporation
Operations 38 Controlled Foreign Corporations 39 Foreign Personal Holding Companies
( FPHCs ) 40 Passive Foreign Investment Companies
( PFICs ) 41 Foreign Investment Companies 42 Foreign Sales Corporations as Export
Incentives 43 Captive Insurance Companies
PART II : A REVIEW OF TAX-RELATED DEVELOPMENTS OCCURRING IN VARIOUS FOREIGN JURISDICTIONS
PART II-A : AMERICAN HAVENS 44 Anguilla 45 Antigua and Barbuda 46 Bahamas 47 Barbados 48 Belize 49 Bermuda 49A Brazil 50 British Virgin Islands 50A Canada 51 Cayman Islands 52 Costa Rica 52A Ecuador 52B Mexico 53 Netherlands Antilles 54 Panama 54A Peru 55 St . Kitts and Nevis 56 St . Vincent 57 Turks and Caicos 58 Uruguay
58A U . S . Territories ( Guam , American Samoa , the U . S . Virgin Islands , and Puerto Rico )
PART II-B : EUROPEAN HAVENS 59 Andorra 60 Austria 61 Belgium 62 Campione d ’ Italia 63 Cyprus 64 Denmark 65 European Union ( EU ) 65A France 66 Gibraltar 67 Guernsey 68 Ireland 68A Isle of Man 69 Jersey 70 Liechtenstein 71 Luxembourg 72 Madeira 73 Malta 74 Monaco 75 Netherlands 75A Russia 76 Samos 76A Spain 76B Sweden 77 Switzerland 77A Ukraine 78 United Kingdom
PART II-C : PACIFIC BASIN AND OTHER HAVENS 78A Australia 78B China 79 Cook Islands 80 Hong Kong 80A India 81 Labuan 82 Liberia 83 Marshall Islands 84 Mauritius 85 Nauru 86 Singapore 87 Vanuatu 88 Qatar and Malaysia
Index
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