Intellectual Property International Trade Tax

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IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

The Upcoming Implementation of the Italian Patent Box Regime

Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more

Alert: Is an Innovation Box Coming to the US?

United States lawmakers are facing increasing pressure from technology and life science industry leaders to adopt an "innovation box" regime to level the playing field with foreign counterparts and prevent significant US job...more

Cassation instance supports tax authorities in Oriflame case

On June 11, 2015, Moscow District Arbitration Court handed down its ruling in the controversial Oriflame case. In the case, the tax authorities challenged the lawfulness of a Russian organization deducting VAT and expenses...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

Outbound IP Transfer in an F Reorganization

In one corner, we have Code §368(a)(1)(F) which generally allows for a corporation to move from one jurisdiction to another without triggering gain or other immediate adverse income tax consequences. The purpose is to allow...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

Taking Your Business International

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...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

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

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

Important royalty withholding tax decision

The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all...more

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

Action 5 - Countering Harmful Tax Practices

Action Item 5 of the BEPS Action Plan commits the Forum on Harmful Tax Practices (“FHTP”) to: “revamp the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous...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

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

Top of Mind - October 2014: Editor's Choice

BYOD: cool but dangerous – 3 HIPAA Security Rule challenges, 7 key precautions - Companies and employees like the idea of bring your own device (BYOD) policies that allow employees to use their personal mobiles for...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

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

The European Technology Index: Technology – An engine for growth?

In 2012, in light of the Euro crisis and uncertainty of a double dip recession, DLA Piper launched the first Tech Index survey. This was to review the perceptions and attitudes of European technology growth in light of market...more

International Tax News - October 2013

COLOMBIA ISSUES TAX HAVENS LIST: 4 THINGS TO NOTE FOR THOSE DOING BUSINESS IN COLOMBIA - Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia...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

John Hancock Loses $560 Million Tax Lawsuit

John Hancock Loses $560 Million Tax Lawsuit by Joseph M. Donegan on August 23, 2013 The U.S. Tax Court recently ruled against the John Hancock Life Insurance Co. in a tax lawsuit involving hundreds of millions in...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

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