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Intellectual Property Tax

Read Intellectual Property Law updates, alerts, news, and legal analysis from leading lawyers and law firms:

Partnering Perspectives - Summer 2017

As we implement the Eversheds Sutherland combination and expand our ability to serve clients around the globe, our US and international teams are working together to analyze issues impacting clients doing business in multiple...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

by Hogan Lovells on

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

In Case You Missed It: Launch Links - June, 2017

by WilmerHale on

Some interesting links we found across the web this week: HBO’s ‘Silicon Valley’ Tackled an Issue That’s all too Familiar to Startups: The Threat of Frivolous Patent Litigation - The threat of frivolous patent...more

Law à la Mode: Special Edition - INTA 2017

by DLA Piper on

The Belgian editorial team is delighted to bring you this special edition of Law a` la Mode, marking the 139th INTA Annual Meeting in Barcelona. Just some of the focuses for this special edition include the dangers of...more

German tax treatment of royalties regarding software license and database licenses – Draft guidance of German Federal Ministry of...

by Hogan Lovells on

Yesterday the German Federal Ministry of Finance (Bundesfinanzministerium) released a draft circular on the German tax treatment of royalties paid for software and database licenses granted by non-resident licensors....more

BEPS Update – Germany on the way to limit the tax deductibility of royalties

by Hogan Lovells on

A new legislative approach of the German tax authorities, which had been leaked in December 2016, was passed on Thursday, 27 April 2017, as one of the very last laws of the current Bundestag prior to the elections in...more

Business Law Update - May 2017

by Barley Snyder on

Through June 19, the Pennsylvania Tax Amnesty Program will waive all penalties and slash the interest rate on outstanding tax delinquencies that existed as of the end of 2015. Both the state and the Pennsylvania Department of...more

Proposed tax changes in Australia a win for IP owners

by DLA Piper on

On 30 March 2017, the Federal Government released the Treasury Laws Amendment (2017 Enterprise Incentives No 1) Bill 2017. The Bill contains a number of significant changes to the tax depreciation of intangible assets....more

Belgium: IP tax incentive - implementing the nexus approach and broadening the scope of application

by DLA Piper on

In 2007, Belgium introduced a patent income deduction (PID) for Belgian companies (and permanent establishments of foreign companies) that derive income from or by means of patents and supplementary protection certificates....more

Window On Washington - This Week in the Nation's Capital - Vol. 1, Issue 2

by Clark Hill PLC on

Budget/Appropriations - April Deadline: The first deal Trump must cut is one to keep the government open past April 28, and here Republicans and Democrats mostly want him to get out of the way. Senate appropriators in...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

by Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

by Bowditch & Dewey on

How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more

Draft interpretation note on withholding tax on royalties

by Hogan Lovells on

The South African Revenue Service has issued a draft interpretation note on the application of the withholding tax imposed on royalties in terms of sections 49A to 49H of the Income Tax Act. ...more

US: Proposed "Border Adjustment Tax” could kill foreign IP holding companies

by Hogan Lovells on

With President Trump in the White House and a Republican majority in both the House and Senate, tax reform is once again high on the agenda. Several weeks ago, President Trump promised “a tax reform bill that will reduce our...more

German cabinet proposes law bill restricting tax relief for royalties to certain "patent boxes"

On January 25, 2017, the German cabinet has resolved on a law bill dubbed "license barrier" as a reaction to the BEPS initiative. If the bill passes parliament, it will mean that – in principle – tax relief will be...more

Doing Business in the UAE

by Latham & Watkins LLP on

Country Background - Formed on 2 December 1971, the UAE is a federal state of seven emirates comprising Abu Dhabi, Ajman, Dubai, Fujairah, Ras Al Khaimah, Sharjah and Umm Al Quwain. The UAE federal constitution...more

BEPS – Germany on the way to limit the tax deductibility of royalties

by Hogan Lovells on

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime...more

The PFIC Regulations Get a Facelift

by Alston & Bird on

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

Cross-border licensing of intangible property: tax and legal issues in the life sciences sectors

by DLA Piper on

Success in the life sciences industry can depend on a company's ability to share knowledge and collaborate with strategic partners while simultaneously protecting from its competitors the valuable information on which its...more

UK Autumn Statement 2016: IPT

by DLA Piper on

No major changes were announced (subject to legislation to be published on 5 December), but we set out below a brief summary of the announcements which are relevant to corporates in the IPT sector....more

McDermott International Legal Highlights November 2016

by McDermott Will & Emery on

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

Preferential tax-deductible costs for transfer of intellectual property rights in IT sector

by DLA Piper on

Polish tax law allows employees to increase their tax-deductible costs with respect to the transfer of copyrights to works that they have created. In general, if a work produced by an employee is of a creative nature and thus...more

India-Mauritius Protocol Seeks to Close Tax Loopholes

by K&L Gates LLP on

Originally published in The Investment Lawyer, Volume 23, Number 9, pages 19–27, September 2016. On May 10, 2016, the Republic of India and the Republic of Mauritius entered into a protocol (the ...more

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

by McDermott Will & Emery on

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

What do Prince, Michael Jackson, and Whitney Houston Have in Common?

by BakerHostetler on

Michael Jackson, Prince and Whitney Houston each revolutionized the music industry and impacted popular music for decades. We all appreciate how Michael Jackson moonwalked across the stage, Prince made it (purple) rain and...more

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