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Tax Intellectual Property General Business

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

Partnering Perspectives - Summer 2017

As we implement the Eversheds Sutherland combination and expand our ability to serve clients around the globe, our US and international teams are working together to analyze issues impacting clients doing business in multiple...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

by Hogan Lovells on

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Law à la Mode: Special Edition - INTA 2017

by DLA Piper on

The Belgian editorial team is delighted to bring you this special edition of Law a` la Mode, marking the 139th INTA Annual Meeting in Barcelona. Just some of the focuses for this special edition include the dangers of...more

BEPS Update – Germany on the way to limit the tax deductibility of royalties

by Hogan Lovells on

A new legislative approach of the German tax authorities, which had been leaked in December 2016, was passed on Thursday, 27 April 2017, as one of the very last laws of the current Bundestag prior to the elections in...more

Business Law Update - May 2017

by Barley Snyder on

Through June 19, the Pennsylvania Tax Amnesty Program will waive all penalties and slash the interest rate on outstanding tax delinquencies that existed as of the end of 2015. Both the state and the Pennsylvania Department of...more

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

The PFIC Regulations Get a Facelift

by Alston & Bird on

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...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

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

by McDermott Will & Emery on

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

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

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

by Pepper Hamilton LLP on

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

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

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

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

California Supreme Court Denies BOE Petition for Review in Lucent Technologies

by McDermott Will & Emery on

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

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

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

by Dentons on

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

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

Law A' La Mode - Issue 17 October 2015

by DLA Piper on

The Netherlands editorial team is delighted to bring you the 17th edition of Law a` la Mode, the quarterly legal magazine produced by DLA Piper’s Fashion, Retail and Design group for clients and contacts of the firm...more

Conflicting State and Federal Laws May Result in Crippling Blows to Business in the Marijuana Industry

by Davis Brown Law Firm on

As of October 2015, four states have legalized marijuana for recreational use: Alaska, Colorado, Oregon and Washington. The recreational marijuana movement—although slow in terms of states following by legalizing use—has had...more

California Court of Appeal Hears Oral Argument in Lucent Technologies

by Reed Smith on

On September 24, the Court of Appeal for the Second District heard oral argument in Lucent Technologies v. State Board of Equalization. The issue before the court was whether telephone switching software is exempt from sales...more

Kyiv Tax Newsletter - August 2015

by Dentons on

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

Corporate E-Note - June 2015

by Burr & Forman on

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

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

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