Science, Computers & Technology Business Organization Tax

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OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: key comparisons

The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises. This...more

Tax Policy Update

NUMBER OF THE WEEK: 40 percent. The average combined federal and state tax rate paid by most U.S.-based firms, according to a Wall Street Journal op-ed by James Freeman today, entitled “The Tax Takeover Craze.” Freeman claims...more

Tech Industry Bulletin

In this Issue: - Corporate: Negotiating Strategies for the Sale of Technology Companies - Intellectual Property: Crowdfunding and Confidentiality for Tech Start-Ups - Real Estate: An Introduction to...more

New York State ALJ Determines Travel Reservation Facilitation Receipts and Online Advertising Receipts Constitute Service Receipts...

There has been significant controversy in New York regarding whether receipts from services—particularly those that may be delivered via the Internet—constitute “service” receipts or “other business receipts” for corporate...more

State and Local Taxation: Headline News and Trends

In This Presentation: - Megatrends and Developments - Business Activity Taxes - Transaction Taxes - Other Issues - Excerpt from Megatrends and Developments: PRIVATE LAWSUITS. CHOOSE...more

The New “Click-Through”?: New York Budget Proposal Requires Marketplace Providers to Collect Tax

On January 21, Governor Cuomo delivered his State of the State address, along with proposing the new budget. The budget has a number of new tax proposals. One of those proposals would have a significant impact on e-commerce...more

MoFo New York Tax Insights - Volume 6, Issue 1 - January 2015

In This Issue: - The Top 10 New York Tax Highlights of 2014 - Tribunal Affirms That a Charter Yacht Is Not Exempt from Use Tax as a Commercial Vessel - Court of Appeals Holds City Transfer Tax Does Not...more

Take Advantage of Washington’s High-Tech Incentives before It’s Too Late!

Two significant Washington research and development tax incentives are set to expire on January 1, 2015: the High Technology B&O Tax Credit for qualified R&D expenditures (“High-Tech Credit”) and the High Technology Sales and...more

IRS Office of Chief Counsel Treated Collaboration Arrangement as Partnership

In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more

Legal Alert: A Trend Emerging? District Court Disallows $1 Billion of Deductions

Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more

Tax Treatment of Deferred Start-Up Costs for Life Science Companies

The pre-commercialization life science company is generally funded with various rounds of financing that are used to research and develop products. During this time frame, life science companies generally do not have a...more

Inside the (Patent) Box: UK Government introduces beneficial tax regime on patent income

Beginning on 1 April 2013, the UK Government will reduce the rate of corporation tax payable in the UK on profits arising from patents and some other forms of intellectual property (“IP”). The reduced tax rate implemented by...more

Strategic Intellectual Property Offshoring Through Outsourcing

Traditionally intellectual property (IP) offshoring has been used by multinational corporations as a way to reduce their global effective tax rates by holding their IP in low tax offshore jurisdictions. The 2009 relocation by...more

Monetizing Life Science Company Net Operating Losses

As in most high-risk businesses, tax losses are an important consideration for life science startups. Indeed, given that only one company in 20 or 30 ultimately succeeds, a tax loss is frequently the only asset the company...more

China 20/20: Legal & Regulatory Developments

In This Issue MOFCOM Issues Measures on Investigation and Handling of Failure on Declaration of Business Operators' Concentration Implementing Regulations for the PRC Bid Invitation and Submission Law Tax...more

Sutherland Salt Shaker Vol. 2 No. 3- March 21, 2011

New Jersey Tax Court Finds “User Error” in Treatment of Extraterritorial Income; Discrimination Train Has Left the Station: U.S. Supreme Court Remands Alabama Railroad Case; Ouch! Taxpayer Seeks to Pierce Its Own Veil; Salt...more

IRS Guidance Regarding Qualifying Therapeutic Discovery Project Credit

On May 21, 2010, the Internal Revenue Service released Notice 2010-45,1 which provides anticipated guidance regarding the filing of claims for a qualifying therapeutic discovery project (“QTDP”) credit. The QTDP credit is a...more

Health Care Reform Advisory: Update on the Billion-Dollar Tax Credit and Grant Opportunity: What Life Sciences Companies Can Do...

In a recent advisory, we reported that the Patient Protection and Affordable Care Act (a.k.a. the health care reform bill) includes $1 billion in tax credits and grants to defray the costs of therapeutic research by small and...more

Health Care Reform Advisory: Billion-Dollar Tax Credit and Grant Opportunity for Life Sciences Companies

Among the varied provisions in the voluminous Patient Protection and Affordable Care Act, a/k/a the Health Care Reform Bill, Congress has appropriated up to $1 billion in tax credits and grants to defray the costs of...more

PLC Review of Russian Law on venture Capital 2010

This is a Q&A review of current Russian law on venture capital investments. The chapter was first published in the PLC Cross-border Private Equity Volume 2: Venture Capital Handbook 2010 and is reproduced with the kind...more

If Your Client is Not Capturing IP-Related Tax Savings They are Likely Leaving Significant Money on the Table

Few companies accurately track the costs and profits associated with the development and deployment of intellectual property. As a result, they are unable to fully capitalize on the tax savings associated with their...more

Notice of Deposition of Corporation Designee

Notice of Deposition for Corporation Designee (officer, employee, etc. of a corporation party as a plaintiff or as a defendant)....more

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