Foreign Tax and Trade Briefs and

International Withholding Tax Treaties Guide

By Walter H. Diamond

An Offshore Investment Book Review by Matt Blackman


Even to the seasoned accountant or lawyer, taxation can be a complex and confusing issue. There is challenge enough to understanding the implications at home without delving into the labyrinth of tax rates and rules of other jurisdictions. However, once reserved for accountants and tax attorneys, this realm requires an understanding by the international businessperson aiming to compete in the New World of global trade and finance where effective tax planning often makes the difference between success and failure. It is primarily for this growing breed; the international entrepreneur, banker, financier, broker, insurance executive, agent, investor, import/export professional, investment analyst as well as the lawyer and accountant that Foreign Tax and Trade Briefs and companion International Withholding Tax Treat Guide were written.

After taking six years to compile in the early post-war period, Briefs was initially published in 1950 and was the first compendium of foreign tax laws ever released. It is still recognized by many professionals as the "bible," according to Mr. Diamond. It has annotated continual changes in tax rates and treaties, growing to encompass more than 125 nations including the more than 60 industrialized nations. Semi-monthly updates insure that all information remains current. Written from an American perspective, Briefs is also useful to tax practitioners and business professionals from other nations with interests in the U.S. and around the globe.

Beginning with the preface, the two-volume work begins outlining the history of growth in trade and investment between the U.S. and the rest of the world. Driven by necessity and with ever increasing momentum, American investment and trade has expanded outward since the Second World War due to a combination of factors such as increasing opportunities abroad and rising costs at home. The U.S. government has worked to encourage this expansion with programs designed to stimulate trade, especially in locating new markets for American products. Growth of economies in Caribbean tax havens and Central American developing nations has been due in no small measure to these incentives and although somewhat diminished, opportunities remain for those with the initiative to discover and utilize them.

Taxation for each country is made easy to understand and explained in eleven specific headings.

      1. Individual taxes.
      2. Partnership or business taxes.
      3. Corporation taxes.
      4. Capital tax.
      5. Dividend tax.
      6. Remittance tax and dollar limit transfer.
      7. Revenue taxes.
      8. Sales taxes.
      9. Real Estate taxes.
      10. Miscellaneous taxes.
      11. Remarks on tax treaties (Section entitled Tax Conventions) and on Investment Guarantees.

Tax incentives including tax-free trade zones, taxation holidays, refunds, exemptions, and tax credits are discussed for each nation. Tax treaties with the U.S. are also explained. The International Withholding Tax Treaty Guide as the name implies, thoroughly covers the topic of tax treaty withholding taxes for all nations covering more than 2,200 treaties. It also discusses taxation of dividends, film and other royalties, interest income, shipping and aircraft income, intellectual rights etc.

Although tax treaties between pure tax havens (with no taxes on income) and nations that tax income are rare, Foreign Tax and Trade Briefs does discuss a number of the well-known no-tax and low-tax offshore financial centers. The Bahamas, Bermuda, the Netherlands Antilles, Barbados, Liechtenstein, Panama, Ireland, Luxembourg, Switzerland and Cyprus are covered. The Channel Islands are discussed in the U.K. section. It is these chapters that will be of interest to readers exploring opportunities to increase tax efficacy. As it is unlikely that tax authorities in high-tax nations will tap you on the shoulder to explain various tax breaks and incentives available in various offshore jurisdictions around the world, it is up to the individual to discover them on their own. It is these gems uncovered and regularly updated that make these publications so valuable.

Walter H. Diamond 85, an expert in foreign taxation and trade, has led a distinguished career. Foreign Tax and Trade Briefs was his first major work and has been published since 1950. The first edition followed a request by then president of the Federal Reserve Bank of New York where Mr. Diamond was Foreign Analyst to keep tabs on taxes for foreign securities and investments. Mr. Diamond also served as Foreign Economist for one of New York City's largest commercial banks. He is author or co-author of such essential publications as Tax Havens of the World, International Trust Laws and Analysis, Tax-Free Trade Zones of the World, International Tax Treaties of All Nations, and Capital Formation and Investment Incentives Around the World.

Foreign Tax and Trade Briefs at $425 US and International Withholding Tax Treaty Guide at $225 are available from Matthew Bender Books.

*RATING 9/10* Reading Level - Advanced to Professional*

Disclaimer: The views expressed are independent and the sole opinion of Matt Blackman who has not and will not receive financial remuneration from the publisher or author for this review. Although great care was taken in writing this review, the author cannot and does not guarantee the accuracy of information contained herein due to its complex nature. Readers are advised to obtain legal counsel before making any investment or estate planning decision. Publisher supplied a review copy of this publication. Note: This column is dedicated to reviewing books on the subject of offshore investing and asset management. It is designed to provide an insight into the publications available to assist readers looking for the best information available for the money.

If you have a comment or question about a review or have read written a publication of interest that you'd like to discuss, please: Email: Matt Blackman at matt@goldhaven.com or FAX (604) 464-6949.


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