Tax International Trade Intellectual Property

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United States Property Investments under Section 956 of the Code

I. Background and Overall Scope of Section 956 - The overall purpose of section 956 is to tax investments made by CFCs in specified categories of “United States property” on a constructive dividend basis. The...more

Action 5 - Countering Harmful Tax Practices

Action Item 5 of the BEPS Action Plan commits the Forum on Harmful Tax Practices (“FHTP”) to: “revamp the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous...more

The new Italian Patent Box is also a “Copyright Box”!

DLA Piper welcomes the adoption of a patent box in our country, a measure which has been publicly hoped for by the most relevant stakeholders. The final approval of the Patent Box, expected by the end of the year, will...more

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning...more

Top of Mind - October 2014: Editor's Choice

BYOD: cool but dangerous – 3 HIPAA Security Rule challenges, 7 key precautions - Companies and employees like the idea of bring your own device (BYOD) policies that allow employees to use their personal mobiles for...more

Franchising In India: Key Considerations For Franchisors Seeking To Grow Their Brands

India recently staged the largest free democratic election in world history, bringing to power the National Democratic Alliance, led by the Bharatiya Janata Par ty, and with it a fresh sense of optimism about India’s economic...more

Argentina: Favorable Venue for Manufacturers Licensing Their Technology/Intellectual Property Rights

Argentina, together with Brazil and Mexico, are Latin America’s three largest economies representing more than 80 percent of the region’s manufacturing output. In addition, Argentina has proven to be a favorable venue for...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

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

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

John Hancock Loses $560 Million Tax Lawsuit

John Hancock Loses $560 Million Tax Lawsuit by Joseph M. Donegan on August 23, 2013 The U.S. Tax Court recently ruled against the John Hancock Life Insurance Co. in a tax lawsuit involving hundreds of millions in...more

NJ Court Broadly Interprets Consumer Contract Protection Statute

NJ Court Broadly Interprets Consumer Contract Protection Statute by Christine M. Vanek on August 12, 2013 Discount restaurant coupons purchased online qualify as contracts under the state’s consumer protection statute,...more

Manufacturing Innovation in America Act Introduced in House

On June 28, Rep. Allyson Schwartz (D-PA) introduced legislation (H.R. 2605) to amend the Internal Revenue Code of 1986 to allow a deduction for "patent box" profit from the use of U.S. patents (and foreign patents in certain...more

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

Energy Newsletter - May 2013

In This Issue: - DISPUTE RESOLUTION: - Oil & Gas Litigation: New Decision May Impede Fracking on Federal Land - Intellectual Property: Non-Practicing Entities (Patent Trolls) Target Oil and Gas...more

Distribution in China – Legal Issues

McDermott Will & Emery is pleased to offer “Distribution in China – Legal Issues*,” a one-stop resource covering distribution in China, including: The business models and legal structures most commonly used for...more

Countdown to The Introduction of The New Patent Box Regime

From 1 April 2013, UK companies will be able to elect into a new regime that applies a lower rate of corporation tax to profits from qualifying intellectual property (IP) rights. The relief will be phased in, culminating on...more

Supreme Court of Canada Establishes Important Principles in Transfer Pricing

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more

New Guidance from the OECD on the Meaning of “Beneficial Owner” for Tax Treaty Purposes

Taxpayers and their advisors should be aware of a significant new development concerning the appropriate withholding tax rate on the payment of cross-border interest, royalties and dividends....more

Cross-Border Retailing: A Guide to Canadian Market Entry

Given our healthy economy, a robust retail market and proximity to the United States, Canada is an increasingly attractive destination for U.S. retail investment. Entering the Canadian retail market can be smooth and...more

IRS Issues Guidance on Outbound Transfers of Intangible Property in Asset Reorganizations

In Notice 2012-39 (the “Notice”), the IRS issued guidance announcing its intention to issue regulations with respect to certain transfers of intangible property by a U.S. corporation to a foreign corporation in a...more

Global Automotive Newsletter - June 2012

In This Issue: - The International Trade Commission: A Powerful Alternative for Patent Holders: What does a patent holder do when component parts that infringe one or more of its patents are imported into the...more

Doing Business in Poland

Table of Contents: - Overview...1 - Forms of Entity.... 1 - Establishing A Business...2 - Specific Form of Doing Business In Poland-Direct Sales...4 - Dispute Resolution Mechanism... 5 - Labor Matters and...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

Tax Efficient Licensing Solutions through the Netherlands

License companies are treated favourably in the Netherlands. In fact, it can be argued that the Netherlands is the world’s best jurisdiction to establish license companies. By virtue of the Netherlands’ extensive...more

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