Tax Intellectual Property

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

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

Kyiv Tax Newsletter - August 2015

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

Draft Legislation Proposes Favorable Treatment for Intellectual Property Transferred to the United States

On July 29, Representatives Charles Boustany, Jr. (R-La.) and Richard E. Neal (D. Mass.) introduced draft legislation to the House Ways and Means Committee that would provide favorable tax treatment on certain intellectual...more

Energy Insights: An Update from the Second Quarter of 2015

In this edition of Seyfarth Shaw’s Energy Insights Newsletter our Energy and Clean Technologies team covers important developments in Q2 2015 for the energy industry including court protection for companies using hydraulic...more

Planning for Potential Significant Tax Breaks

On July 29, 2015, two members of the U.S. House of Representatives introduced draft legislation for public comment that would provide U.S. companies with a significant tax break on profits derived from qualifying intellectual...more

The Upcoming Implementation of the Italian Patent Box Regime

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?

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

Corporate E-Note - June 2015

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

Cassation instance supports tax authorities in Oriflame case

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

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

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

Taking Your Business International

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

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

ESPN Productions Scores Win with Indiana Tax Court’s Ruling Prohibiting Public Access to its Tax Returns and Trade Secrets

On April 9, 2015, ESPN Productions, Inc. recorded its biggest play of the day in the Indiana Tax Court, when the Court granted the Company’s request to seal from public disclosure tax returns, a production services agreement,...more

The Italian IP Box – the final version converted into Law

On 24 March 2015 the Investment Compact Decree (published on January 2015) was finally converted into law, with a number of modifications to the Italian patent box (IP Box) approved at the end of last year. ...more

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

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