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. The book provides up-to-date information on the legal, tax, business, financial, social, political, technological, geographical, and regional factors to consider when developing and implementing customized planning strategies for clients. Packed with case studies, the book guides readers on how 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, and respond effectively to changing tax planning situations in specific havens and financial centers.

The latest release includes updates on:

• Chapter 2 discusses the Tax Court holding that a partnership was engaged in the conduct of a U.S. trade or business based on the activities of its asset manager, and was also a “dealer in securities” subject to the mark-to-market accounting rules of section 475.
• Chapter 5 talks about a case in which the Tax Court noted that the scope of section 904(f)(3) allows taxpayers to offset U.S. tax liability with a foreign tax credit, but does not cap the taxpayer’s gain to the amount of corresponding loss.
• Chapter 18 explains an IRS legal memorandum concluding that restricted stock units compensating an employee for work performed for both a U.S. employer and its controlled foreign corporation are wages subject to federal income tax withholding, but only grants for work performed in the United States will be subject to FICA.
• Chapter 26 examines what it means to “willfully” (or “non-willfully”) file a false income tax return or fail to report foreign bank accounts.

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