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Royalties Internal Revenue Service U.S. Treasury

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Fenwick & West LLP

New Proposed FTC Regulations Provide Limited Relief

Fenwick & West LLP on

In the newly released Proposed Foreign Tax Credit (FTC) Regulations, Treasury provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the Final FTC Regulations that...more

McCarter & English, LLP

Taxpayers That Paid The Net Investment Income Tax Or The Additional Medicare Tax Should Consider Filing Protective Claims For...

Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Dorsey & Whitney LLP

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

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

McDermott Will & Emery

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

Troutman Pepper

Final Regulations Released Revising The Tax Treatment Of Sales-Based Royalties And Vendor Allowances

Troutman Pepper on

In December 2010, the IRS and Treasury proposed regulations that required the allocation of sales-based royalties and vendor allowances exclusively to property that has been sold (or for inventory property, deemed sold under...more

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