Intellectual Property Tax

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Prevailing Party Awarded Taxable Costs from Production to Opposing Party (California)

Apple Inc. v. Samsung, 2014 WL 4745933 (N.D. Cal. Sept. 19, 2014). In this intellectual property case, the plaintiff sought to recover around $1.5 million in costs for producing documents to an online hosted...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

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

A Clarifying Development – “Canadian Content” Tax Credit Regulations Amended

The October 4, 2014 Canada Gazette (being vol. 148, no. 40), contained something of note for Canadian film and TV lawyers: amendments to the Income Tax Act regulations which govern the “Canadian content” tax credits for...more

Estate Planning Tips from the Loss of a Hollywood Icon

A very notable woman in the entertainment industry (other than Joan Rivers) passed away recently—Lauren Bacall. Lauren, born Betty Joan Perske, left a true legacy in the entertainment world, as well as a couple of good...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

Washington Insight - July 2014

In This Issue: - Progress Toward Comprehensive Patent Reform Stalls - As Attention Turns to a Border Supplemental, a Twelve Bill Omnibus Seems Certain - Highways, Taxes, and Partisanship: The Next...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

Taxation Of Copyright Sales: Ordinary Income Or Capital Gain?

Tax day presents several interesting questions for copyright holders, not the least of which is how the Internal Revenue Service (IRS) will treat income from the sale or exclusive license of a copyright. If a copyright is a...more

Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

Today, the Maryland Court of Appeals issued its highly anticipated decision in Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury; Future Value, Inc. v. Comptroller of the Treasury. The court held that under the...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

46 sites blocked, watch your banners!

The Italian tax police seized 46 websites streaming videos in breach of the copyright holders, but is also going after entities “supporting” such sites through banners published on them so starting a new approach in the fight...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

Alabama Legislative Update - Week 3: Mother Nature and Old Man Winter Disrupt Legislative Schedule

Alabama was taken by storm last week. Among the thousands stranded on highways or the fortunate ones at home or at work were scores of State Legislators who could not get to Montgomery or who could not leave Montgomery. The...more

"The Estate Planner" – January/February 2014

In this issue: - Planning For The Net Investment Income Tax - The Stretch IRA: A Simple Yet Powerful Estate Planning Tool - Do You Know How To Address IP In Your Estate Plan? - Estate Planning Red...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

Legislative Update Report No. 2013-23 -- Dec 13, 2013

In This Article: Federal Government; Alberta; British Columbia; Manitoba; New Brunswick; Newfoundland; Northwest Territories; Nova Scotia; Nunavut; Ontario; Prince Edward Island; Québec/Quebec; Saskatchewan; and Yukon....more

Copyright measures against Google’s indexing of news contents

The Italian Government has just approved a law decree that apparently will introduce copyright-related measures aimed at sorting disputes relating to the usage of news contents by search engines and news aggregators....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

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