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Internal Revenue Service Intellectual Property Protection

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Shook, Hardy & Bacon L.L.P.

NCAA’s $2.8 Billion Athlete Revenue Settlement Receives Final Approval

Not only does Judge Claudia Wilken’s final approval of the In re: College Athlete NIL Litigation settlement provide $2.576 billion in damages for settlement class members, it changes the rules of the game for current and...more

Fenwick & West LLP

A Recent Tax Ruling Has Made ANDA Litigation Less Burdensome for Generics

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In Actavis v. U.S., a case at the intersection of tax law and patent law, the Federal Circuit held that generic drug companies’ Hatch-Waxman litigation expenses are “ordinary and necessary business expenses” and can be...more

Miller Canfield

The Tax Court Recently Decides Two Research Credit Cases: One Favorable on Funding (Smith) and One Unfavorable on the Four-Part...

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Taxpayers had mixed success in two recent research credit cases in the United States Tax Court. In Smith v. Commissioner, the taxpayer was an architectural firm....more

Fleurinord Law PLLC

The IRS Estate Tax Battle Over Michael Jackson’s Legacy

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When the King of Pop passed away in 2009, he left behind more than just a rich legacy of music and pop culture. He also left behind a colossal estate that soon became entangled in one of the most scrutinized, drawn-out...more

McDermott Will & Emery

IRS Issues Final Rules on Intangible Property Repatriations

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With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly...more

Gerald Nowotny - Law Office of Gerald R....

Elena Ruiz and the Cuban Sandwich - The Double Irish with Dutch Sandwich Version for Closely Held Business Owners - Using...

I have been a major fan of Afro-Cuban (Salsa) and Brazilian Bossa Nova music since high school. Most of you know by now that I grew up in the Panama Canal Zone. By the time I got to West Point in the summer of 1978, it was...more

Gray Reed

That’s All Capital Gain Right? Income Taxes and Intellectual Property Monetization

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Intellectual property (“IP”) is typically monetized either by sale or (royalty generating) license agreements. The Code often allows sales to be taxed at preferential capital gains rates while simple royalties are ordinary...more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

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Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

ArentFox Schiff

10 Legal Issues for Nonprofit and Association Leadership in 2024

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As 2024 gets underway, the nonprofit sector will continue to face new challenges in addition to grappling with ongoing challenges that continue to impact the sector. Our interdisciplinary team, serving thousands of nonprofits...more

Gray Reed

The Taxman, Technology Litigation and Cavalier Settlement Structures

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Intellectual property (“IP”) is hugely important to businesses. Given that importance, IP owners must occasionally litigate against the unauthorized use of their technology. The costs of such litigation and appurtenant...more

Mintz - Venture Capital & Emerging Companies...

Section 409A Valuations: Mastering the Art and Science in a Volatile Venture Market

Within the unpredictable landscape of start-ups and private companies, market volatility can significantly alter a company’s financial trajectory. An integral part of navigating this volatility is understanding the role and...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Insights: Other Regulatory Developments

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more

Arnall Golden Gregory LLP

The Pitch - October 2023

The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more

Seyfarth Shaw LLP

If You Have NFTs in Your Retirement Account – Beware

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Seyfarth Synopsis: New IRS guidance suggest that many NFTs may be considered “collectibles,” causing concerns for IRAs and individually-directed accounts under a tax-qualified plan....more

Foley & Lardner LLP

Common Diligence Issues for Startup and Emerging Technology Companies

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As an emerging or startup technology company seeking funding, your focus is likely on your product - it is the core of your business. That being said, how you protect your technology and set up the company that owns it can be...more

Fenwick & West LLP

Can you Prepay a Section 367(d) Royalty? IRS Says No (This Time)

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Taxpayers with royalties owing from a foreign affiliate may wish to negotiate a prepayment of the future royalty stream for a lump sum price. This could include accelerating foreign source income or repatriating cash from a...more

Stinson LLP

Pass Interference: Potential Tax Implications of NIL Collectives in College Sports

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Conference realignments. TV deals continuing to soar. Name, image and likeness. If there is one thing that has recently come to define college sports, it is the constant flux and the ebb and flow of change permeating the...more

ArentFox Schiff

Is It Time for a Test Drive in the Metaverse?

ArentFox Schiff on

Buying a car has evolved from the days of brick and mortar dealerships to e-commerce, where consumers can select their preferred dealer, reserve, order, finance, and purchase a new or used vehicle in a seamless transaction....more

Foster Garvey PC

Sports & Entertainment Spotlight - June 2021

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Athletes and entertainers are people, too. Albeit, incredibly talented people, but deserving of the same treatment with dignity and respect as how we would want ourselves to be treated. For better or worse, sometimes their...more

Foster Garvey PC

Sports & Entertainment Spotlight - April 2021 #3

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“Happy” Tax Day to those of you here in the United States celebrating/commiserating (noting of course that certain taxpayers have until May 17 to file their returns this year). Like taxes, this installment of the Spotlight...more

Haug Partners LLP

Don’t Get Caught In the Conflict: U.S. Versus Brazilian IP Transfer Pricing Rules

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During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), Charles Rettig, proclaimed, “[I am] not a commissioner who believes that the IRS loses...more

Morgan Lewis

New Laws And Regulations: Insights For 2020

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A constantly evolving framework of laws governing how multinational businesses can contact customers to how nonprofits report business income to how overtime is calculated and paid will influence how companies do business...more

Fenwick & West LLP

Fenwick’s Top 10: Our Most Popular Articles of 2019

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In 2019, we published analysis to help tech and life sciences companies navigate U.S. tax law changes, an evolving IP landscape and new privacy regulations such as the California Consumer Privacy Act. We also tracked venture...more

Fenwick & West LLP

Intellectual Property Bulletin - Summer 2018

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In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

Troutman Pepper Locke

Cannabis Industry FAQ

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Can marijuana businesses receive federal copyright protection? Yes. The requirements for registration with the U.S. Copyright Office are that the work is original, creative and fixed in some form of expression. These...more

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