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Tax International Trade Intellectual Property

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

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

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

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

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

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

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

Brexit Update: What’s Next for the Global Marketplace

by McDermott Will & Emery on

In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...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

U.S. Tax Implications of Offshore Migration of Intellectual Property

by Dorsey & Whitney LLP on

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

The Trade Facilitation and Enforcement Act of 2015 Is on its Way to the President’s Desk

Last Thursday, the U.S. Senate voted 75-20 to agree to the conference report on H.R. 644, the Trade Facilitation and Enforcement Act of 2015 (the “Act”) sending the legislation to President Obama’s desk for enactment. The Act...more

Senate Passes Trade Facilitation And Trade Enforcement Act - Comprehensive Customs bill addresses several key topics

by King & Spalding on

On February 11, 2016, the Senate passed the Trade Facilitation and Trade Enforcement Act of 2015 (H.R. 644) by a 75-20 vote. Today’s action constitutes acceptance by the Senate of a conference agreement reached by House and...more

Economic sanctions and trade

by Dentons on

Easing of economic sanctions against Iran - The International Atomic Energy Agency’s recent certification that the Government of Iran has met its obligations under the P5+1 Nuclear Agreement resulted in the United States...more

Adoption of the ‘Trade Mark Package’ and practical implications

by Reed Smith on

On 23 March 2016, the European Union Trade Mark Regulation (dated 16 December 2015) comes into force. As part of the package of changes introduced by the Regulation, the ‘Community trademark’ will change its name to the...more

RF Supreme Court Judges deny review of Oriflame Cosmetics by the Judicial Panel for Economic Disputes

by Dentons on

RF Supreme Court Ruling No. 305-K?15-11546 of 14.01.2016 denied the transfer of the cassation appeal by OOO Oriflame Cosmetics against adverse judgments to the Judicial Panel for Economic Disputes for consideration in a court...more

Use of Provisional Patent Applications

by Stoel Rives LLP on

Provisional patent applications became available on June 8, 1995 in response to the General Agreement on Tariff and Trade (the GATT treaty) whereby applicants in the United States are able to establish an early filing date by...more

International News: Focus on Tax - Issue 3, 2015

by McDermott Will & Emery on

The breadth of the articles contained in our Focus on Tax this issue demonstrates the perennial importance of this topic to global businesses and international high net worth individuals. We examine topics ranging from...more

US China Trade War — TPP, Three False Trade Arguments, China President Trip, Trade, Customs, IP/Patent Securities

by Dorsey & Whitney LLP on

As indicated in more detail below, the Import Alliance will have meetings on November 17th and 18th in Washington DC. On the afternoon of November 17th, we will meet in our Washington DC office and then on November 18th meet...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

New IP Legislation Under Consideration Regarding Tax Relief for Income Generated From IP Assets

by Lane Powell PC on

McGraw Hill Financial, Oracle and Facebook, announced they are forming a group called “American Innovation Matters” (AIM) to lobby Congress to revise the U.S. international tax code rules in an effort to encourage innovation...more

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

by Morrison & Foerster LLP on

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

The Upcoming Implementation of the Italian Patent Box Regime

by McDermott Will & Emery on

Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more

Alert: Is an Innovation Box Coming to the US?

by Cooley LLP on

United States lawmakers are facing increasing pressure from technology and life science industry leaders to adopt an "innovation box" regime to level the playing field with foreign counterparts and prevent significant US job...more

Cassation instance supports tax authorities in Oriflame case

by Dentons on

On June 11, 2015, Moscow District Arbitration Court handed down its ruling in the controversial Oriflame case. In the case, the tax authorities challenged the lawfulness of a Russian organization deducting VAT and expenses...more

Guide to Doing Business in New Zealand: The Country and Government (Updated)

THE COUNTRY - New Zealand is an island nation in the South Pacific with a population of approximately four million five hundred thousand people from a diverse range of ethnic backgrounds. A significant majority of 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

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