International Law & Trade, Tax Law, Intellectual Property

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

by Anthony Diosdi | Moskowitz LLP on 5/22/2013

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

As Nonprofits Expand Their Global Reach, a Special Focus on Tax, Trademarks and the Foreign Corrupt Practices Act

by Charles Kolstad, Lindsay B. Meyer, Andrew D. Price, Jeffrey S. Tenenbaum | Venable LLP on 5/14/2013

In this presentation: - Introduction - Trademark/Brand Strategy and Protection - U.S. Foreign Corrupt Practices Act and Anti-Corruption - Cross-Border Tax Planning and Compliance Please see...more

Energy Newsletter - May 2013

by King & Spalding on 5/3/2013

In This Issue: - DISPUTE RESOLUTION: - Oil & Gas Litigation: New Decision May Impede Fracking on Federal Land - Intellectual Property: Non-Practicing Entities (Patent Trolls) Target Oil and Gas...more

Distribution in China – Legal Issues

by John Huang, Frank Schoneveld, Winston Zhao | McDermott Will & Emery on 4/4/2013

McDermott Will & Emery is pleased to offer “Distribution in China – Legal Issues*,” a one-stop resource covering distribution in China, including: The business models and legal structures most commonly used for...more

Countdown to The Introduction of The New Patent Box Regime

by Désirée Fields, Tom Scott, Hiroshi Sheraton | McDermott Will & Emery on 1/21/2013

From 1 April 2013, UK companies will be able to elect into a new regime that applies a lower rate of corporation tax to profits from qualifying intellectual property (IP) rights. The relief will be phased in, culminating on...more

Supreme Court of Canada Establishes Important Principles in Transfer Pricing

by Claire M.C. Kennedy, Martin P.J. Kratz Q.C., Darrel H. Pearson | Bennett Jones LLP on 12/3/2012

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more

New Guidance from the OECD on the Meaning of “Beneficial Owner” for Tax Treaty Purposes

by Dentons on 10/24/2012

Taxpayers and their advisors should be aware of a significant new development concerning the appropriate withholding tax rate on the payment of cross-border interest, royalties and dividends....more

Cross-Border Retailing: A Guide to Canadian Market Entry

by Bennett Jones LLP on 10/23/2012

Given our healthy economy, a robust retail market and proximity to the United States, Canada is an increasingly attractive destination for U.S. retail investment. Entering the Canadian retail market can be smooth and...more

Baker & McKenzie: The Global Employer: A Primer On International Labor and Employment Issues

by Baker & McKenzie Australia on 9/17/2012

Editors’ Note - In today’s global economy, a growing international focus is changing the political, economic, employment and labor landscape. Some US multinationals are expanding their workforces around the globe, and...more

IRS Issues Guidance on Outbound Transfers of Intangible Property in Asset Reorganizations

by Orrick, Herrington & Sutcliffe LLP on 8/28/2012

In Notice 2012-39 (the “Notice”), the IRS issued guidance announcing its intention to issue regulations with respect to certain transfers of intangible property by a U.S. corporation to a foreign corporation in a...more

Global Automotive Newsletter - June 2012

by Miller Canfield on 6/30/2012

In This Issue: - The International Trade Commission: A Powerful Alternative for Patent Holders: What does a patent holder do when component parts that infringe one or more of its patents are imported into the...more

Doing Business in Poland

by Miller Canfield on 5/19/2012

Table of Contents: - Overview...1 - Forms of Entity.... 1 - Establishing A Business...2 - Specific Form of Doing Business In Poland-Direct Sales...4 - Dispute Resolution Mechanism... 5 - Labor Matters and...more

Inside the (Patent) Box: UK Government introduces beneficial tax regime on patent income

by Morrison & Foerster LLP on 5/1/2012

Beginning on 1 April 2013, the UK Government will reduce the rate of corporation tax payable in the UK on profits arising from patents and some other forms of intellectual property (“IP”). The reduced tax rate implemented by...more

Tax Efficient Licensing Solutions through the Netherlands

by Cees Frans Greeven on 3/13/2012

License companies are treated favourably in the Netherlands. In fact, it can be argued that the Netherlands is the world’s best jurisdiction to establish license companies. By virtue of the Netherlands’ extensive...more

Co-Production Updates

by Heenan Blaikie LLP on 3/9/2012

Two items of note relating to the issue of international treaty co-productions which I believe indicate their re-emergence as a way of producing (especially in the current financial climate). First, Telefilm Canada...more

Taxpayer Wins “Beneficial Ownership” Case: Velcro Canada Inc. v. The Queen

by Osler, Hoskin & Harcourt LLP on 2/29/2012

The Tax Court of Canada recently allowed the taxpayer’s appeal in Velcro Canada Inc. v. The Queen. The issue on appeal was whether a Dutch company was the beneficial owner of royalties paid to it by a Canadian...more

"Beneficial Owner" - CRA'S Assessment Of Velcro Doesn't Stick

by Dentons on 2/28/2012

The Tax Court has once again considered the meaning of the phrase “beneficial owner” for purposes of the tax treaty between Canada and the Netherlands. It has also once again ruled in favour of the taxpayer in...more

Week of January 9, 2012 on ILNToday - A Roundup

by International Lawyers Network on 1/17/2012

It has been one busy week on ILNToday, with some excellent contributions from our members around the world! My top five posts for this week are: •Intellectual Property Bulletin of Kochanski Zieba Rapala & Partners: Our...more

WTO Accession of the Russian Federation - Implications for Alcohol and Tobacco Sectors

by King & Spalding on 12/22/2011

Russia’s accession to the World Trade Organization (WTO) will create opportunities to increase exports of alcohol and tobacco products to Russia. On 16 December 2011, WTO Members accepted the terms of the Russian Federation’s...more

WTO Accession of the Russian Federation - Implications for Pharmaceuticals and Medical Devices

by King & Spalding on 12/22/2011

Russia’s accession to the World Trade Organization (WTO) will create opportunities to increase exports of pharmaceutical products and medical devices. On 16 December 2011, WTO Members accepted the terms of the Russian...more

Doing Business In Canada

by Osler, Hoskin & Harcourt LLP on 10/31/2011

Doing Business in Canada is designed to give business executives, counsel and potential investors from foreign countries a concise overview of Canada’s legal and economic framework and key business legislation. For those...more

Life Sciences Update - October 2011

by Baker & McKenzie Australia on 10/4/2011

This is the October 2011 edition of the Life Sciences Update. In this issue: - R&D tax offset legislation passed by Parliament - Raising the Bar - Interchangeability of drugs, not doses -...more

New VAT regime for "business to consumer" suppliers of telecoms, broadcasting and electronic services

by john Menton on 6/30/2011

With effect from 1 January 2015, a new VAT regime will apply across Europe for “business to consumer” suppliers of telecoms, broadcasting and electronic services. This new regime will have a material impact on...more

Intensive Efforts Underway to Conclude WTO Doha Trade Negotiations

by King & Spalding on 2/2/2011

Implications for Companies with International Trade Interests Following calls by world leaders at the G20 and APEC meetings in November to conclude the Doha Round of multilateral trade negotiations by the end of 2011,...more

Ireland as a location of Intellectual Property Management

by john Menton on 12/31/2010

There is a low corporation tax rate in Ireland and it has what is considered to be a business-friendly taxation regime. In certain circumstances a company carrying on a trade of exploiting intellectual property which it has...more

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International Law & Trade › Tax Law › Intellectual Property