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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

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

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

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

UK Finance Bill 2016: Royalty Withholding Tax

by DLA Piper on

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

In Case You Missed It: Launch Links - March 2016 #3

by WilmerHale on

Some interesting links we found across the web this week: The SEC could change the requirements for investing in startups, and that’s not good - With its new equity crowdfunding rules soon to take effect, the...more

eBook Doing Business in Massachusetts: A Guide to U.S. and Massachusetts Law for Non-U.S. Businesses

by Foley Hoag LLP on

This guide is intended to provide foreign business-people with an introduction to the basic kinds of laws and regulations that affect the conduct of business in the United States, and particularly in The Commonwealth of...more

The Arbitration Court declares it legal to deduct license fees for use of trademarks

by Dentons on

The Arbitration Court declares it legal to deduct license fees for use of trademarks - The Moscow Arbitration Court rendered the Decision of December 31, 2015 on case No. ?40-153860/15. The case was essentially about the...more

Abolition of Luxembourg IP Box Regime

by DLA Piper on

On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the...more

Kyiv Tax Newsletter - August 2015

by Dentons on

Improvement of the e-management system for value added tax - The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on...more

Corporate E-Note - June 2015

by Burr & Forman on

In this Issue: - IRS Issues Guidance on Portability: The IRS recently issued final regulations that provide guidance on the federal estate and gift tax applicable exclusion amount, in general, as well as the...more

Outbound IP Transfer in an F Reorganization

by Charles (Chuck) Rubin on

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

Taking Your Business International

by Carlton Fields on

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

Share Plan changes tabled and diced

by FPA Patent Attorneys on

The Division 83A (employee share plan) amendments were tabled in Parliament yesterday, 25 March 2015, and include welcome improvements on the exposure draft released last January. Start-ups - Most of the changes...more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update: March 2015

by Reed Smith on

This is a brief update on recent Pennsylvania tax developments. Governor Wolf’s FY16 Budget Proposal—combined reporting and more On March 3, Gov. Tom Wolf (D) presented his first budget address as Pennsylvania’s 47th...more

How to Mess Up Your Start-Up

by Varnum LLP on

There are lots of good articles out there about how to succeed.  Here are a few pointers on how to mess up your company from a legal perspective.  - Pick a name without checking it out. You may not be the first one to...more

Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

by Reed Smith on

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

Virginia Adopts Narrow Definition of “Royalty” for Purposes of its Intangible Expense Add-Back

by Reed Smith on

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

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

by Frank Brunetti on

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

IRS Begins Crackdown of Small Businesses

by Joseph Donegan on

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

The IRC §409A Minefield

by James McDonough on

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

Kodak Receives Final Approval to Make Bankruptcy Emergence

by Joel Glucksman on

Kodak Receives Final Approval to Make Bankruptcy Emergence by Joel R. Glucksman on September 5, 2013 Photography pioneer Eastman Kodak Co. has experienced a rough 19 months after seeking Chapter 11 bankruptcy protection...more

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