Langer On Practical International Tax Planning Focus On 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 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 study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.

"Basic International Taxation provides a uniquely comprehensive overview of the basic principles of the international taxation and considers these in the context of practical planning guidance. The analysis of the practical application of these principles is supported by a detailed review of current international tax practices by leading professionals in over sixty jurisdictions worldwide. "Volume II: Practice includes practical guidance on international tax planning techniques, the use of offshore financial centres for international tax planning, a brief country tax profile of over sixty countries, an analysis of anti-avoidance rules and an overview of some of the current issues in international taxation.

The book is based around a case study of a fictitious Italian family with an abundance of personal and corporate tax issues. The work is presented in ten chapters, each covering a specific principle of international tax planning, such as Is the advice lawful? and Why are trusts useful in tax planning? Each chapter is split into two distinct sections. The first section analyses the law applicable to the principle in question, and the second puts this into context by reference to the case study. Accountants, bankers, lawyers, students, tax advisers and managers of trust companies will benefit from studying The Principles of International Tax Planning, either in depth or as a useful reference book. Because the book has been written by a firm specializing in International taxation, it considers the same questions and issues from the perspective of a number of different jurisdictions, such a France, Italy, South Africa, Switzerland, the UK and the US. Whether you are just interested in international tax, or whether international tax is your livelihood, your horizons will be broadened by reading this book, and you will have fun while doing so!