By Richard S. Lehman
SEMINAR OUTLINE
I. Principle Objectives
A. Limited Personal and Asset Liability
B. Single U.S. Tax
C. Avoid Double Taxation – U.S. and Country of Investor
D. Confidentiality
E. Tax Planning
(1) Eliminate U.S. Taxation of Real Estate Income and Gains
(2) Eliminate U.S. Estate and Gift Tax
(3) Eliminate U.S. Branch Tax on Foreign Corporations
(4) Single Tax
(5) Deferral of Payment of Tax
(6) Reduce Tax Rates
II. Basics
A. Tax Rates
B. Taxable Persons and Entities
(1) Foreign Individual Investor
(2) Limited Liability Company of Partnership
(3) The U.S. Corporation
(4) Foreign Corporation
(5) Foreign Trusts
III. Planning Techniques
A. Avoidance of the Double Tax
B. Elimination of the U.S. Estate and Gift Tax and the Branch Tax
C. The Foreign Trust – U.S. Estate Tax Avoidance and Income Tax Benefits
D. Tax Bracket Advantages and Individual Planning
E. Avoidance of the Double Tax
F. Tax Free Income
G. Partially Tax Free Income
H. Tax Treaties







