Practical International Tax Planning

Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.

Publication surveying all aspects of international tax planning including the effective use of foreign financial centres and tax havens. Subjects deal with are: the legal framework of international tax planning; tax planning in the U.S.A. and outside the U.S.A.; offshore bases outside the U.S.A.; fundamentals of international taxation; import practice. Other subjects are: foreign investment in U.S. real estate and minimizing FIRPTA tax on dispositions of U.S. real estate; offshore banks and trust companies; foreign anti-avoidance measures, etc. The book takes into account the impact of the 1986 Tax Reform Act as well as other changes resulting from new income tax treaties, mutual assistance treaties, and significant changes in the laws of other countries and other revisions.

This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.

This book provides background material concerning why and how to use foreign tax havens. The various chapters discuss why tax havens exist, a survey of havens, tax haven activities, special uses of tax havens, the legal framework, anti-avoidance measures, major no-tax havens, territorial tax havens, Britain's low-tax Caribbean havens, the Netherlands Antilles and its unique status, Britain's sterling area havens, European holding and domiciliary companies, and choosing the best tax haven.

This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.