News & Analysis as of

Intangible Property

Mistake in Your Credit Report? The Latest Spokeo Decision Suggests You May Have A Case.

In the 9th Circuit’s August 15, 2017 decision in Robins v. Spokeo, the latest in the long-running legal debate about when a consumer cause of action exists for a data breach, the 9th Circuit has declared that inaccuracies in...more

Proposed tax changes in Australia a win for IP owners

by DLA Piper on

On 30 March 2017, the Federal Government released the Treasury Laws Amendment (2017 Enterprise Incentives No 1) Bill 2017. The Bill contains a number of significant changes to the tax depreciation of intangible assets....more

Treatment of Bitcoin Under U.S. Property Law

by Perkins Coie on

In this white paper, we analyze the treatment of bitcoin under applicable U.S. property law. We conclude that property interests should exist in bitcoin under such law, and that multiple sources of persuasive authority...more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

Expect Focus - International, Spring, March 2017

by Carlton Fields on

Rules of the (International) Road - An Overview - Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally,...more

Tightening the Tax Screws on International IP Structures

by Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

MTC Adopts Allocation and Apportionment Regulations

In a rare special meeting on February 24, 2017, the Multistate Tax Commission (MTC) adopted amendments to the MTC’s Model General Allocation and Apportionment Regulations (Model Regulations) that it has worked on since 2014....more

Digital assets create new complications for estate planning

by Thompson Coburn LLP on

“Digital assets” encompasses a wide variety of things, from your email and Facebook accounts to your iTunes music to your electronically stored data to your domain name to bitcoins. Some of them may have actual value, while...more

California FTB Schedules Interested Parties Meeting on Short Notice to Discuss Issues in the Regulations on Sourcing Income from...

by McDermott Will & Emery on

The California Franchise Tax Board has scheduled an Interested Parties Meeting to discuss proposed changes to its apportionment regulations. Several years ago, when the statute called for sourcing receipts from services and...more

New Sales Tax Law Affecting Construction Industry to Take Effect

by Smith Anderson on

A number of amendments to North Carolina’s sales tax laws applicable to the construction industry took effect January 1, 2017. These amendments will provide welcome relief to many contractors engaged in new construction....more

Cross-border licensing of intangible property: tax and legal issues in the life sciences sectors

by DLA Piper on

Success in the life sciences industry can depend on a company's ability to share knowledge and collaborate with strategic partners while simultaneously protecting from its competitors the valuable information on which its...more

Out-of-State Taxpayers Can Reduce Pennsylvania Franchise Tax Under Wynne; Conduct Manufacturing? Your Franchise Tax Should Be Zero...

by Reed Smith on

The Pennsylvania franchise tax has finally expired: 2015 is the last year that taxpayers are required to report and pay it. Because the tax rate has decreased over time, it can be little more than a nuisance for many...more

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

by McDermott Will & Emery on

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

Final Regulations Clarify the Definition of “Real Property” Under the REIT Rules

by Morrison & Foerster LLP on

On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more

Software are “Goods” after all under Commercial Agency Regulations

by Bryan Cave on

On 1 July 2016, the UK High Court held in the case of The Software Incubator Limited -and- Computer Associates UK Limited that intangible software may qualify as “goods” for the purposes of the application of the Commercial...more

Intellectual Property Issues for Government Contractors

by PilieroMazza PLLC on

OVERVIEW - - Intellectual property - Types of intellectual property - Trademarks - Trade secrets - Copyrights - Patents - Data right Please see full Presentation below for more...more

Sell now to avoid paying higher taxes upon disposition of goodwill and other intangibles

by Dentons on

The 2016 Federal Budget proposed changes to the Income Tax Act (Canada), expected to come into force effective January 1, 2017, that will alter the manner in which the sale of certain intangible property, such as goodwill, is...more

California FTB to Discuss Apportionment of Combined Group Income

by McDermott Will & Emery on

The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for combined reporting groups with both...more

New York Law Governed Bonds are Sufficient “Property” for U.S. Bankruptcy Court Jurisdiction

by Reed Smith on

To qualify as a “debtor” under the U.S. Bankruptcy Code, an entity must reside, have a place of business or property in the U.S. It is common for non-U.S. entities that file for chapter 11 protection to rely on the “property”...more

Focus on Tax Strategies & Developments - October 2015

by McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Proposed Regulations Dramatically Change U.S. Federal Tax Treatment of Outbound Transfers of Intangible Property

On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would...more

California Tax Developments - A Reed Smith Quarterly Update (2nd Quarter 2015)

by Reed Smith on

Case Updates - BREAKING NEWS: Gillette Oral Arguments Scheduled - The California Supreme Court has scheduled oral arguments in the Gillette Multistate Tax Compact case. This comes three years after the California...more

Unusual Like-Kind Exchanges

by Alston & Bird on

Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more

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

by Morrison & Foerster LLP on

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

Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

by McDermott Will & Emery on

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

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