Tax Intellectual Property

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Share Plan changes tabled and diced

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

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

Employees vs. Independent Contractors: The Consequences of Misclassification

The distinction between independent contractors and employees carries more burdens, consequences, and decisions than ever before. In addition to the tax consequences, there are health care compliance consequences, workers’...more

EU patent box regimes - The way ahead

EU WITHDRAWS INVESTIGATION - Many countries in Europe, including the UK, The Netherlands, Belgium, Luxembourg, Spain, France and Hungary have special tax regimes for profits derived from specific types of intellectual...more

Insight on Estate Planning - February/March 2015

In This Issue: - Estate planning for young families: Flexibility is the key - Get smart when tackling estate planning for intellectual property - Avoiding undue influence claims - Estate Planning Pitfall:...more

Australia: What is and is not a “royalty” for withholding tax purposes? Latest key court decision

By Jock McCormack, James Newnham, Matthew Cridland and Eddie Ahn Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal...more

The new Italian patent box is also a trademark & design box

In November 2014 we said that the Italian patent box is also a copyright box. The patent box regime, adopted at the end of last year with the 2015 Financial Bill, was recently modified by the so called “Investment Compact...more

How to Mess Up Your Start-Up

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

Global Tax News - January 2015

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

The Artist’s Legacy – Business and Legal Planning Issues

Sheppard Mullin attorneys Christine Steiner and Lauren Liebes recently joined Weston Naef, Getty Photography Curator Emeritus, and ASA appraiser Jennifer Stoots for “What Will Become of Your Legacy”, a panel discussion at Los...more

Important royalty withholding tax decision

The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all...more

Department Shifts Position on Sourcing of Intangibles

While the Department’s Information Notice focuses primarily on the sourcing of revenues from services, it also addresses the sourcing of receipts from intangibles – in a manner seeming to be directly at odds with previously...more

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

Spanish tax reform: Corporate Income Tax

The new legislation will be applicable for fiscal years starting as from 1 January 2015, although some new measures will only be effective as from 2016. The main objectives of this tax reform are: on one hand,...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

The new Italian Patent Box!

On 15 October 2015 the Italian Government submitted to Parliament the so called “Stability Law 2015?, a bill containing a number of measures aimed at vitalizing the Italian economy and boosting grow in the system, including...more

Prevailing Party Awarded Taxable Costs from Production to Opposing Party (California)

Apple Inc. v. Samsung, 2014 WL 4745933 (N.D. Cal. Sept. 19, 2014). In this intellectual property case, the plaintiff sought to recover around $1.5 million in costs for producing documents to an online hosted...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

Patent Box or Mystery Box?

The Italian Government recently approved the “patent box”, a tax relief system for the incomes deriving from the exploitation of industrial property. This could be a good news. Around 6 months ago we campaigned for...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

A Clarifying Development – “Canadian Content” Tax Credit Regulations Amended

The October 4, 2014 Canada Gazette (being vol. 148, no. 40), contained something of note for Canadian film and TV lawyers: amendments to the Income Tax Act regulations which govern the “Canadian content” tax credits for...more

Estate Planning Tips from the Loss of a Hollywood Icon

A very notable woman in the entertainment industry (other than Joan Rivers) passed away recently—Lauren Bacall. Lauren, born Betty Joan Perske, left a true legacy in the entertainment world, as well as a couple of good...more

Three Point Shot

Female Football Player Throws Flag at LFL over Bare Wages - The three-year championship run of the Los Angeles Temptation was snapped in 2013 when the upstart Chicago Bliss, led by the quarterback and two-time league...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

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