Description
Review the new tax rules, prior approaches to offshore IP planning, and review potential alternative structures.The Tax Cuts Jobs Act of 2017 along with actions taken by the European Union have significantly changed the U.S. tax rules applicable to intellectual property. The new rules will require many companies to revisit their IP tax strategies, and possibly cause them to repatriate their offshore IP back to the U.S.
Date: 2019-11-01 Start Time: End Time:
Learning Objectives
Overview of Intellectual Property • Trademarks, Copyrights, Patents, Trade Secrets etc.
Tax Cuts and Jobs Act 2017 • Changes to Tax Treatment of IP
• Section 250 • Foreign Derived Intangible Income
• Section 1221 • Capital Assets
• Section 1235 • Patents
• Section 951 • Global Intangible Low Taxed Income
• Section 965 • Accumulated Earnings and Profits
Impact of TCJA of IP Planning
• Outbound Transfers of IP
• Existing Offshore IP Holding Companies • to Keep or to Close?
• Tax Haven Economic Substance Requirement Imposed by the European Union
• Us Developed IP
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Charles S. Kolstad-Withers Bergman LLP