Langer on Practical International Tax Planning (Fifth Edition) 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 delivers 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.
Highlights from the fourth release of the Fifth Edition include:
- Revised section on Dual Nationality explains that when a taxpayer works in the United States and another jurisdiction, it presents challenges under the Social Security system, including double taxation, incomplete coverage, or loss of continuity of coverage (see section 11:4.1).
- Revised section on Foreign Bank Account Reporting (FBAR) Rules discusses how a “willful violation” of the FBAR reporting requirement includes both knowing and reckless violations, even though more is required to sustain a criminal conviction for a willful violation of the same requirement; in sum, “willfulness” includes “recklessness” (see section 30:2.3).
- New section on Sale or Exchange of Partnership Interest explores regulations issued in November 2020, which (1) retain the ten-year exception as an exception to the determination of deemed sale effectively connected gain and loss; and (2) provide rules for the sourcing of deemed sales gain and loss (see section 34:3.2[E]).
- New section on Foreign Life Insurance Companies examines the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b), for tax years beginning after December 31, 2018 (see section 43:2.1[D]).
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