Intellectual Property General Business Tax

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McDermott International Legal Highlights November 2016

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

Arm’s Length Royalty Rates Save Medtronic from $1.36 Billion Tax Deficiency

Addressing whether certain intercompany technology license agreements were negotiated at arm’s length, the US Tax Court rejected the Internal Revenue Service’s (IRS’s) alleged $1.36 billion tax deficiency and determined that...more

UK Finance Bill 2016: Royalty Withholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

A Look at Tax Issues of the Life Sciences and Tech Industries

Wolters Kluwer had the opportunity this past week to sit down with Pepper Hamilton LLP partners Todd Reinstein, Washington, D.C., and Joan Arnold, Philadelphia, to discuss current tax issues particularly relevant to the life...more

U.S. Tax Implications of Offshore Migration of Intellectual Property

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

Patent Box – Ultimi Aggiornamenti Dall’Agenzia Delle Entrate

As known the cd. "Patent Box" allows companies carrying out activities Research & Development to opt, as from the tax in 2015, for a taxation regime facilitated the income generated from the direct exploitation or indirect...more

Economic sanctions and trade

Easing of economic sanctions against Iran - The International Atomic Energy Agency’s recent certification that the Government of Iran has met its obligations under the P5+1 Nuclear Agreement resulted in the United States...more

California Supreme Court Denies BOE Petition for Review in Lucent Technologies

Last week, the California Supreme Court denied the State Board of Equalization’s (BOE’s) petition for review in Lucent Technologies, Inc. v. State Bd. of Equalization, No. S230657 (petition for review denied Jan. 20, 2016)....more

RF Supreme Court Judges deny review of Oriflame Cosmetics by the Judicial Panel for Economic Disputes

RF Supreme Court Ruling No. 305-K?15-11546 of 14.01.2016 denied the transfer of the cassation appeal by OOO Oriflame Cosmetics against adverse judgments to the Judicial Panel for Economic Disputes for consideration in a court...more

The Arbitration Court declares it legal to deduct license fees for use of trademarks

The Arbitration Court declares it legal to deduct license fees for use of trademarks - The Moscow Arbitration Court rendered the Decision of December 31, 2015 on case No. ?40-153860/15. The case was essentially about the...more

US China Trade War — TPP, Three False Trade Arguments, China President Trip, Trade, Customs, IP/Patent Securities

As indicated in more detail below, the Import Alliance will have meetings on November 17th and 18th in Washington DC. On the afternoon of November 17th, we will meet in our Washington DC office and then on November 18th meet...more

Law A' La Mode - Issue 17 October 2015

The Netherlands editorial team is delighted to bring you the 17th edition of Law a` la Mode, the quarterly legal magazine produced by DLA Piper’s Fashion, Retail and Design group for clients and contacts of the firm...more

Conflicting State and Federal Laws May Result in Crippling Blows to Business in the Marijuana Industry

As of October 2015, four states have legalized marijuana for recreational use: Alaska, Colorado, Oregon and Washington. The recreational marijuana movement—although slow in terms of states following by legalizing use—has had...more

California Court of Appeal Hears Oral Argument in Lucent Technologies

On September 24, the Court of Appeal for the Second District heard oral argument in Lucent Technologies v. State Board of Equalization. The issue before the court was whether telephone switching software is exempt from sales...more

Kyiv Tax Newsletter - August 2015

Improvement of the e-management system for value added tax - The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on...more

Corporate E-Note - June 2015

In this Issue: - IRS Issues Guidance on Portability: The IRS recently issued final regulations that provide guidance on the federal estate and gift tax applicable exclusion amount, in general, as well as the...more

Guide to Doing Business in New Zealand: The Country and Government (Updated)

THE COUNTRY - New Zealand is an island nation in the South Pacific with a population of approximately four million five hundred thousand people from a diverse range of ethnic backgrounds. A significant majority of the...more

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

ESPN Productions Scores Win with Indiana Tax Court’s Ruling Prohibiting Public Access to its Tax Returns and Trade Secrets

On April 9, 2015, ESPN Productions, Inc. recorded its biggest play of the day in the Indiana Tax Court, when the Court granted the Company’s request to seal from public disclosure tax returns, a production services agreement,...more

The Italian IP Box – the final version converted into Law

On 24 March 2015 the Investment Compact Decree (published on January 2015) was finally converted into law, with a number of modifications to the Italian patent box (IP Box) approved at the end of last year. ...more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update: March 2015

This is a brief update on recent Pennsylvania tax developments. Governor Wolf’s FY16 Budget Proposal—combined reporting and more On March 3, Gov. Tom Wolf (D) presented his first budget address as Pennsylvania’s 47th...more

EU patent box regimes - The way ahead

EU WITHDRAWS INVESTIGATION - Many countries in Europe, including the UK, The Netherlands, Belgium, Luxembourg, Spain, France and Hungary have special tax regimes for profits derived from specific types of intellectual...more

The new Italian patent box is also a trademark & design box

In November 2014 we said that the Italian patent box is also a copyright box. The patent box regime, adopted at the end of last year with the 2015 Financial Bill, was recently modified by the so called “Investment Compact...more

How to Mess Up Your Start-Up

There are lots of good articles out there about how to succeed.  Here are a few pointers on how to mess up your company from a legal perspective.  - Pick a name without checking it out. You may not be the first one to...more

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

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