The document discusses strategies for offshore investments to avoid U.S. tax consequences, focusing on sheltering a client's portfolio from U.S. taxation during their stay in the United States. It highlights the use of PPVA investment accounts for tax-deferred retirement planning and managing UBTI for tax-exempt entities.
doj/DataSet10/EFTA01454211.pdf
{"title":"FEATURE: INVESTMENTS","document_date":"2012-12","document_type":"correspondence","document_subtype":"memo","reference_numbers":["DB-SDNY-0112192","SDNY_GM_00258376","EFTA01454211"]}