Intellectual Property Taxation

Intellectual Property Taxation

Author: Jeffrey A. Maine

Publisher:

Published: 2004

Total Pages: 520

ISBN-13:

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The 2012 Student Update is accessible by clicking here. This casebook is the first to provide interdisciplinary coverage of two exciting areas of the law: intellectual property and taxation. Valuable business assets are increasingly in the form of intangible assets such as patents, trade secrets, copyrights, trademarks, trade names, and computer software. Moreover, with the arrival of global, e-commerce transactions on the Internet, new forms of intellectual property, such as domain names and web contents, have emerged. The creation, development, acquisition, and sale and licensing of these intellectual property assets have significant tax consequences. Authors Maine and Nguyen adopt the problem method in addressing intellectual property taxation, and cover both general and special tax principles governing different forms of intellectual property. The book's ten chapters are each devoted to the taxation of a major IP transaction such as intellectual property research and development, acquisitions, sales and licenses, and judgment awards and settlements. Every chapter contains a set of relevant problems, a summary of the black letter law, and excerpts of important cases and administrative pronouncements.


The Intellectual Property Holding Company

The Intellectual Property Holding Company

Author: Jeffrey A. Maine

Publisher: Cambridge University Press

Published: 2017-12-07

Total Pages: 311

ISBN-13: 1108325920

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Many companies that have become household names have avoided billions in taxes by 'parking' their valuable intellectual property (IP) assets in holding companies located in tax-favored jurisdictions. In the United States, for example, many domestic companies have moved their IP to tax-favored states such as Delaware or Nevada, while multinational companies have done the same by setting up foreign subsidiaries in Ireland, Singapore, Switzerland, and the Netherlands. In this illuminating work, tax scholar Jeffrey A. Maine teams up with IP expert Xuan-Thao Nguyen to explain how the use of these IP holding companies has become economically unjustified and socially unacceptable, and how numerous calls for change have been made. This book should be read by anyone interested in how corporations - including Gore-Tex, Victoria's Secret, Sherwin-Williams, Toys-R-Us, Apple, Microsoft, and Uber - have avoided tax liability with IP holding companies and how different constituencies are working to stop them.


Kritika: Essays on Intellectual Property

Kritika: Essays on Intellectual Property

Author: Hanns Ullrich

Publisher: Edward Elgar Publishing

Published: 2018-07-27

Total Pages: 215

ISBN-13: 1788971167

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The fields of intellectual property have broadened and deepened in so many ways that commentators struggle to keep up with the ceaseless rush of developments and hot topics. Kritika: Essays on Intellectual Property is a series that is designed to help authors escape this rush. It creates a forum for authors who wish to more deeply question, investigate and reflect upon the evolving themes and principles of the discipline.


The Fundamentals of Federal Taxation

The Fundamentals of Federal Taxation

Author: John A. Miller

Publisher:

Published: 2010

Total Pages: 640

ISBN-13:

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The third edition of The Fundamentals of Federal Taxation is a problem-based, transaction-oriented treatment of the basics of federal taxation. It features a balanced approach toward tax planning and tax policy and is structured for easy accessibility through the use of forty-two chapters, each of which can readily be covered in one, or occasionally two, class sessions. A new chapter in this edition brings together the various exclusions, deductions and credits concerning education. This is a topic of particular relevance to students that often receives scattered treatment in other books. Thoroughly up to date, this edition incorporates the changes arising from the American Taxpayer Relief Act of 2012, the so-called ¿fiscal cliff¿ legislation. The authors also prepare an annual supplement each August. The first half of the book provides students with an understanding of the overall structure of the federal income tax. This part culminates in two major review problems that assist students in integrating the knowledge gained. Thereafter, the book covers various major topics of taxation¿including real estate taxation, intellectual property taxation, family taxation, tax consequences of litigation, and deferred compensation -- with an emphasis on tax planning. It is designed to give students an appreciation for how the law of taxation connects with everyday events of American life. The book also contains chapters on corporate and partnership income taxation, international income taxation and the federal wealth transfer taxes in order to introduce students to those important areas of tax law. In this cogent, straightforward treatment of a complex subject, the topics, the selection of cases, and the design of the problems are all calculated to make tax fun and thought-provoking. This edition is available in both hard copy and electronic versions. A teacher¿s manual with complete solutions to all of the problems is available.


Intellectual Property for Executives

Intellectual Property for Executives

Author: Raymond J. Hegarty

Publisher:

Published: 2019-02-11

Total Pages: 100

ISBN-13: 9781796680461

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Whether you are a corporate executive, international policy maker or motivated student, "Intellectual Property for Executives" will help you grasp an exciting area that continues to evolve.Intangible assets encompass formal intellectual property (IP) such as patents, trademarks, copyright and trade dress and other sources of corporate value such as trade secrets, knowhow and reputation. Together they represent an emerging asset class with unlimited opportunity, but also with so many gaps:*In multinational corporations and innovative firms, enterprise value has become more than 80% intangible, but management techniques, accounting principles and tax rules were all developed in an era when a firm's value was driven by tangible assets such as land, buildings and machinery.*Large firms have become proficient at playing the game of moving intangible assets to offshore locations, thereby reducing their tax bills. Indeed, in some industries, tax strategy has become a primary tool of competition. Governments have scrambled to catch up and ensure that taxes are collected fairly.*In 2017, the OECD base erosion and profit shifting (BEPS) action plan was implemented in a multilateral instrument by more than 70 countries, and corporate tax departments are now trying to figure out how to establish "intangible substance" to match their choice of domicile for their IP holdings."Intellectual Property for Executives" is for people who live in those gaps. It is also for executives who are looking for an overview of how to make sense of it all.The book is organised in three sections. *The first part sets the scene - a quick history of IP systems, how IP got on the executive agenda, USA public policy regarding IP and a special chapter on the growth of China as an IP power.*The middle part speaks about the taxation of intangibles, double taxation treaties and introduces the concept of "substance" in intellectual property business.*The final section puts it all together with guidance on how to build "substance" into corporate governance, local leadership, value-creating DEMPE activities, building local capabilities and conducting an IP audit.Intangible value in has already established its dominance in enterprises. With further growth in autonomous vehicles, VR, AR, 3-D printing, artificial intelligence, blockchain, big data and robots, it will become even more important to master intellectual property and intangible value.


Federal Taxes on Gratuitous Transfers

Federal Taxes on Gratuitous Transfers

Author: Joseph M. Dodge

Publisher: Aspen Publishing

Published: 2014-12-09

Total Pages: 679

ISBN-13: 1454860421

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This book deals with the federal income tax as it bears on gratuitous transfers and with the federal wealth transfer taxes. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. Features: Emphasis on text, statutes, and regulations, rather than cases (especially cases that involve routine application of law to facts) "Building block" organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students High-profile authorship in Joseph M. Dodge (a highly regarded tax specialist), Wendy C. Gerzog, and Bridget J. Crawford (both well-established in the field) The book reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. For example, special valuation rules are treated as basic, as opposed to being just "tacked on" as other books treat them. More emphasis on valuation and use of FLPs than in other books. Valuation is introduced early on and integrated with other material Integration of related income tax materials, including income taxation of estates and trusts Relation of tax doctrine to tax planning strategies Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems