Tax Havens and Their Use By United States Taxpayers: An Overview; A Report to the Commissioner of Internal Revenue, the Assistant Attorney General ... the Treasury (Tax Policy) (Classic Reprint)

A nti-A buse Measures 51 1. Accumulated earnings tax 51 2. Transfer pricing 52 3. Sections 367 and 1491 52 4. Personal holding companies 54 5. Foreign personal holding companies 54 6. Section 269 55 7. Foreign investment companies 55 8. Controlled foreign corporations 56 9. Dispositions of stock of controlled foreign corporations 58 10. Dispositions of patents to foreign corporations 58 V. Patterns of Use of Tax Havens 59 A. Tax A voidance v. Tax Evasion 59 B. Transfers to a Tax Haven Entity 61 1. Transfer Pricing 62 2. Transfers of Assets Other than by Transfer Pricing 63 a. Transfers to Tax Haven Corporations Scope of 367 63 b. Transfers Not Reorganizations 66 C. Transactions Through a Controlled Entity 68 1. Tax Planning Minimizing Tax and Maximizing the Foreign Tax Credit 69 2. Holding Companies 72 3. Sales Activities 74 4. Services and Construction 79 5. Transportation 84 6. Insurance 86 7. Banking 90 D. Transactions Through an Entity which is not Controlled 91 E. Principal Patterns of Abusive Tax Haven Use Predominently by Promoters and by Individual Taxpayers 94 1. Background 95 2. Patterns of Use 95 a. Investment Companies 95 b. Trading Company 96 c. Holding Companies 97 d. Shelters 97 (i )C ommodities 98 (ii) Movies 100 (iii) Foreign situs property 101 e. Foreign Trusts 101 f. Double Trusts 104 g. Generating Deductions 105 h.
(Typographical errors above are due to OCR software and don't occur in the book.)

About the Publisher

Forgotten Books is a publisher of historical writings, such as: Philosophy, Classics, Science, Religion, History, Folklore and Mythology.

Forgotten Books' Classic Reprint Series utilizes the latest technology to regenerate facsimiles of historically important writings. Careful attention has been made to accurately preserve the original format of each page whilst digitally enhancing the aged text.