Monthly Minute | January 2020
A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more
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