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Transfer Pricing Intellectual Property Protection

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | Tax Strategies in the COVID-19 Economic Downturn: Loss Planning and Transfer Pricing - May 1st, 1:00...

As you assess the operational impact of COVID-19 on your business, you may need to reconsider your tax planning strategies. Join us for a discussion on tax planning opportunities and pitfalls in light of market valuation...more

Haug Partners LLP

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

Haug Partners LLP on

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

Hogan Lovells

Transfer pricing in the new global economy

Hogan Lovells on

Driven by ever-advancing technologies, today’s multinationals need to quickly adapt to new ways of doing business — a process that can often leave them more vulnerable to risk including tax and transfer pricing, especially...more

Seyfarth Shaw LLP

The Valuation Of Trade Secrets

Seyfarth Shaw LLP on

Any business professor will tell you that the value of companies has been shifting markedly from tangible assets, “bricks and mortar,” to intangible assets like intellectual property (IP) in recent years....more

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