Tax Implications for Intellectual Property Transactions
$295
About the Course
Is your firm at risk of being penalized by the Internal Revenue Service for mischaracterizing intellectual property transactions or reporting unsupportable royalty rates?
Is your firm paying more taxes than necessary after consummating intellectual property transactions? Could a deeper understanding of tax issues help structure patent sales or licensing transactions to save both parties money and resolve stalled negotiations?
If your answer to any of these questions is “yes,” this unique and highly informative webinar is essential.
The following are among the issues discussed in this webinar:
- •The criteria that may trigger FBI criminal charges related to trade secret misappropriation.
- •When transactions involving patent family members may be treated differently for tax purposes, such as sales versus licenses.
- •What triggers “super royalties” under Section 367(d) of the Internal Revenue Code and their duration and consequences.
- •How transactions must be structured to qualify for Foreign Derived Intangible Income (FDII) treatment and applicable tax rates.
- •Under what conditions individuals may deduct 20% of the tax imposed on royalty revenue.
- •The impact of withholding taxes on royalties remitted to U.S. citizens by non-U.S. entities and the role of foreign tax credits.
- •Tax deferral strategies involving offshore IP, Subpart F consequences, controlled foreign corporations, and definitions of active licensing and marketing.
- •How to structure IP transactions in light of Global Intangible Low-Taxed Income (GILTI) and Qualified Business Asset Investment (QBAI).
- •The conditions required to qualify for Section 1235 capital gains treatment.
Course Leaders
Phyllis A. Guillory, Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry
Ms. Guillory has more than twenty years of experience in cross-border transactions, advising clients on international tax planning, business structuring, foreign investments, and minimizing income and transfer tax exposure. Her background includes accounting and experience with a major international accounting firm.
Aly Z. Dossa, Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry
Aly Dossa focuses on intellectual property counseling and litigation for technology-driven companies. He advises clients on global IP strategy, patent and trademark prosecution, licensing, due diligence, and adversarial proceedings before the PTAB and TTAB.
Course Length
Approx. 1.5 hours
Pricing
$295.00 per user