Generally, an “inversion” is a transaction in which a non-U.S. corporation directly or indirectly acquires substantially all of the properties held by a U.S. corporation or partnership, after which the former owners of that...more
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
4/18/2016
/ Exceptions ,
Foreign Subsidiaries ,
Intra-Group Transactions ,
IRS ,
Patents ,
PFIC ,
Portability ,
Proposed Regulation ,
Royalties ,
Subpart F ,
Tax Reform ,
Transfer of Assets ,
U.S. Treasury