Tax Intellectual Property

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Arm’s Length Royalty Rates Save Medtronic from $1.36 Billion Tax Deficiency

Addressing whether certain intercompany technology license agreements were negotiated at arm’s length, the US Tax Court rejected the Internal Revenue Service’s (IRS’s) alleged $1.36 billion tax deficiency and determined that...more

What do Prince, Michael Jackson, and Whitney Houston Have in Common?

Michael Jackson, Prince and Whitney Houston each revolutionized the music industry and impacted popular music for decades. We all appreciate how Michael Jackson moonwalked across the stage, Prince made it (purple) rain and...more

High Stakes: Investing in a Legal Marijuana Business

Considering diversifying with a high-risk investment? Heard the lure of the “green rush” toward a possible $100 billion legal marijuana industry? Before you write that check... Please see full Article below for...more

Brexit Update: What’s Next for the Global Marketplace

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

The Death of Prince Rogers Nelson – An Estate Tax Controversy Likely To Follow

Many of our readers have asked me about the likely controversy that will ensue following the death of Prince. In fact, two readers feel, since I have been reporting about some of the controversy surrounding the Estate of...more

The Battle Between the Estate of Michael Jackson and the IRS Continues

In March 2014, I reported on the all-out battle that was ensuing in the U.S. Tax Court between the IRS and the Estate of Michael Jackson over the value of the late pop singer’s estate. It began in 2013, when the estate...more

UK Finance Bill 2016: Royalty Withholding Tax

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

Four Lessons Learned from Prince’s Estate (So Far)

Several of the events surrounding the initial administration of Prince’s estate provide lessons applicable to all estate plans, not just celebrity estate plans. If You Don’t Have an Estate Plan, the State Will Write...more

3D Printing: Good Reads/What Executives Should Be Thinking About

With our successful, filled-to-capacity “Thinking in 3D” April 21, 2016 conference still very much in the rear-review mirror, here are some articles worth reading. First, on the day of the conference, the Patent Office...more

Forget That Prince Had No Will, What About the Estate Tax Problems?

There has been a fair amount of buzz in the days after Prince’s death about his estate plan, whether he has a Will, whether he did or did not do any planning. Time will see this out. Prince’s heirs at law appear at this time...more

A Look at Tax Issues of the Life Sciences and Tech Industries

Wolters Kluwer had the opportunity this past week to sit down with Pepper Hamilton LLP partners Todd Reinstein, Washington, D.C., and Joan Arnold, Philadelphia, to discuss current tax issues particularly relevant to the life...more

Finance Deadline Week/One Month and Counting

Midnight Thursday marked the deadline for all finance bills to make their way through their respective chambers before today’s Passover Break. Omnibus Budget Bills - By the end of the week, the House combined eight...more

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

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

Patent Box – Ultimi Aggiornamenti Dall’Agenzia Delle Entrate

As known the cd. "Patent Box" allows companies carrying out activities Research & Development to opt, as from the tax in 2015, for a taxation regime facilitated the income generated from the direct exploitation or indirect...more

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

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

Washington Insight - February 2016

Further Observations From Campaign 2016 - With the first votes having been cast, former Governor Ehrlich shares his candid observations and predictions about the Democratic and Republican candidates’...more

Nigerian Power Sector: Opportunities and Challenges for Investment in 2016

A summary of the existing power sector in Nigeria, current key initiatives, and opportunities and challenges for developers, investors and lenders. Introduction - During the launch of Power Africa in 2013, President...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

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

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

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

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

Adoption of the ‘Trade Mark Package’ and practical implications

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

California Supreme Court Denies BOE Petition for Review in Lucent Technologies

Last week, the California Supreme Court denied the State Board of Equalization’s (BOE’s) petition for review in Lucent Technologies, Inc. v. State Bd. of Equalization, No. S230657 (petition for review denied Jan. 20, 2016)....more

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

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

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

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

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