News & Analysis as of

Royalties Proposed Regulation

McDermott Will & Emery

Weekly IRS Roundup November 21 – November 25, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 21, 2022 – November 25, 2022...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

Freeman Law

Federal Income Tax Characterization of Transactions Involving Computer Programs

Freeman Law on

The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....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

Understanding the SEC’s Proposed New Mining Disclosure Rules: Questions and Answers

Dorsey & Whitney LLP on

On June 16, 2016, the SEC proposed a major overhaul of the disclosure requirements for companies that are engaged in material mining operations, including royalty companies. The proposed rules would replace the SEC’s...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

Beveridge & Diamond PC

DOI Proposes Overhaul Of Federal And Indian Mineral Lease Royalty Valuation Standards

On January 6, 2015, the Department of the Interior’s Office of Natural Resources Revenue (“ONRR”) issued a proposed regulation that would substantially modify existing regulations in 30 C.F.R. Part 1206 for the valuation for...more

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