Intellectual Property General Business Tax

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United States Property Investments under Section 956 of the Code

I. Background and Overall Scope of Section 956 - The overall purpose of section 956 is to tax investments made by CFCs in specified categories of “United States property” on a constructive dividend basis. The...more

Spanish tax reform: Corporate Income Tax

The new legislation will be applicable for fiscal years starting as from 1 January 2015, although some new measures will only be effective as from 2016. The main objectives of this tax reform are: on one hand,...more

The new Italian Patent Box is also a “Copyright Box”!

DLA Piper welcomes the adoption of a patent box in our country, a measure which has been publicly hoped for by the most relevant stakeholders. The final approval of the Patent Box, expected by the end of the year, will...more

The new Italian Patent Box!

On 15 October 2015 the Italian Government submitted to Parliament the so called “Stability Law 2015?, a bill containing a number of measures aimed at vitalizing the Italian economy and boosting grow in the system, including...more

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning...more

Patent Box or Mystery Box?

The Italian Government recently approved the “patent box”, a tax relief system for the incomes deriving from the exploitation of industrial property. This could be a good news. Around 6 months ago we campaigned for...more

Three Point Shot

Female Football Player Throws Flag at LFL over Bare Wages - The three-year championship run of the Los Angeles Temptation was snapped in 2013 when the upstart Chicago Bliss, led by the quarterback and two-time league...more

Franchising In India: Key Considerations For Franchisors Seeking To Grow Their Brands

India recently staged the largest free democratic election in world history, bringing to power the National Democratic Alliance, led by the Bharatiya Janata Par ty, and with it a fresh sense of optimism about India’s economic...more

The BEPS Initiative: Redefining International Tax Planning?

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint. That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20...more

Argentina: Favorable Venue for Manufacturers Licensing Their Technology/Intellectual Property Rights

Argentina, together with Brazil and Mexico, are Latin America’s three largest economies representing more than 80 percent of the region’s manufacturing output. In addition, Argentina has proven to be a favorable venue for...more

Division of Tax Appeals Rules Patent License Fees Not Subject to Sales Tax in New York

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in favor of a medical device and technology company on the question of whether patent license fees that the company charged to its...more

Corporate & Tax E-Note - June 26, 2014

In This Issue: - SBA Ups Size Standards, Allowing 8,400 Firms to Become Small Biz - Auditors Want to Limit Reporting of 'Critical Audit Matters' - House Approves Permanent Extension of Small Business Tax...more

Weekly Update from the NC State House - May 2014: After a very busy first two days of session last week, the General Assembly...

Another Hectic Week - After a very busy first two days of session last week, the General Assembly returned to Raleigh this week with a fully packed agenda. Among other things, they took up fracking, regulatory reform,...more

Legal Alert: Maryland Court of Appeals: Out-of-State Delaware Holding Companies Licensing Patents to Parent Company Doing Business...

Today, the Maryland Court of Appeals held that Maryland may tax out-of-state Delaware holding companies that license patents to their parent company, which was doing business in Maryland. Gore Enterprise Holdings, Inc. v....more

“Boxed Into A Corner”?: Australian Government Confirms That It Is Considering “Patent Box” Tax Rules To Assist Manufacturers

Australia’s Assistant Treasurer has confirmed that the Government will consider the so-called “patent box” tax rules to assist Australian manufacturers of patented goods. Such rules are directed to lowering tax rates on...more

Virginia Adopts Narrow Definition of “Royalty” for Purposes of its Intangible Expense Add-Back

In a recent ruling, the Virginia Department of Taxation determined that payments made by a taxpayer to an affiliated corporation were not "royalty" payments and should not have been added back to the taxpayer’s Virginia...more

Global Tax Report - September 2013: Intellectual Property Tax Planning

In This Issue: - United States: Benefits of Intangible Property Migrations - United Kingdom: Innovation: The Name of the Game - Germany: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Within the...more

How “Taxing” Does a Patent Transfer Have to Be?

Whether you are transferring patent or acquiring rights in a patent, the tax consequences can vary greatly depending on how the transfer is structured. The IRS has recently issued a document (Legal Advice by Field Attorney...more

NJ Court Broadly Interprets Consumer Contract Protection Statute

NJ Court Broadly Interprets Consumer Contract Protection Statute by Christine M. Vanek on August 12, 2013 Discount restaurant coupons purchased online qualify as contracts under the state’s consumer protection statute,...more

Manufacturing Innovation in America Act Introduced in House

On June 28, Rep. Allyson Schwartz (D-PA) introduced legislation (H.R. 2605) to amend the Internal Revenue Code of 1986 to allow a deduction for "patent box" profit from the use of U.S. patents (and foreign patents in certain...more

Spotlight on Tennessee: Intangible Expense Settlement Program – ACTION Required by September 30, 2013

The Tennessee Department of Revenue (Department) has issued Notice #13-06, dated June 2013, encouraging taxpayers subject to the Tennessee Excise Tax who took deductions for "intangible expenses" paid to affiliated or related...more

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

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

IRS Taking Tough Stand On Benefits And Burdens Of Ownership In Recent Section 199 ILM And Tax Court Cases

On April 1, the Internal Revenue Service (IRS) released ILM 201313020 (ILM) in response to an IRS Appeals Division request. It concludes that planning and development activities undertaken by a publisher of books and other...more

Taxation Of Computer Software Sales: Ordinary Income, Capital Gain, Or Both?

The taxation of computer software is complex, confusing, and in some circumstances, uncertain; although self-created computer software is routinely sold today, especially with the significant increase in the number of...more

The UK Patent Box – Clawing Some Money Back from the Taxman

As of April 1st, companies paying UK corporation tax can take advantage of a new tax regime, dubbed the “Patent Box,” to reduce their tax burden. Here we explain why this new regime has been put in place and how and why it...more

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