Intellectual Property Tax

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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

Advertising News & Analysis - May 2014

In this issue: - Leave Your Claims at the Border - Delaware Suit Shows You Can’t Escheat the Tax Man - FDA Sets Limit on Fishy Omega-3 Nutrient Value Claims - Your Guide to Post-Grant Patent...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

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

Investors Plead Guilty to Rig Bids at New Jersey Municipal Tax Auctions

Investors Plead Guilty to Rig Bids at New Jersey Municipal Tax Auctions by Frank L. Brunetti on October 3, 2013 Two financial investors who purchased municipal tax liens pleaded guilty today for their roles in a...more

Ecotality Files for Chapter 11 Bankruptcy

Ecotality Files for Chapter 11 Bankruptcy by Joel R. Glucksman on October 3, 2013 Ecotality, a green-energy company backed by the U.S. government, has followed in the footsteps of many other electric car battery...more

All a Twitter: Why IPOs Are Back

All a Twitter: Why IPOs Are Back by Dan Brecher on September 24, 2013 Twitter, Inc. recently announced plans for an initial public offering (IPO). The news confirmsthat companies are increasingly deciding it's a good...more

GateHouse Media Seeks Bankruptcy Protection

GateHouse Media Seeks Bankruptcy Protection by Joel R. Glucksman on September 19, 2013 GateHouse Media, Inc., a company that owns more than 400 community newspapers and websites, announced its plans to seek bankruptcy...more

San Bernardino Commits to Mediation ‘Outline’

San Bernardino Commits to Mediation ‘Outline’ by Joel R. Glucksman on September 17, 2013 One week after a U.S. Bankruptcy Judge ruled that the city of San Bernardino is eligible to seek protection under the provisions...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

IRS Begins Crackdown of Small Businesses

IRS Begins Crackdown of Small Businesses by Joseph M. Donegan on September 13, 2013 Small businesses may face increased scrutiny from the Internal Revenue Service, which recently announced that it believes small...more

American Arbitration Association Issues Rule Update for Commercial Arbitration

American Arbitration Association Issues Rule Update for Commercial Arbitration by Robert Levy on September 12, 2013 The American Arbitration Association (AAA), which handles over 100,000 disputes each year, recently...more

The IRC §409A Minefield

The IRC §409A Minefield by James F. McDonough, Jr. on September 11, 2013 Tax professionals frequently encounter non-qualified deferred compensation plans (“NQDCA”) in the context of an estate or business. NQDCA’s...more

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