Intellectual Property Taxation: Transaction and Litigation Issues, Second Edition, 2017 Cumulative Supplement

Intellectual Property Taxation: Transaction and Litigation Issues, Second Edition, with accompanying CD-ROM, considers, on a comparative basis, the tax implications of major business transactions involving both traditional and emerging forms of intellectual property. The authors analyses strike a perfect balance between technical tax considerations and the complexities of intellectual property transactions. The Second Edition provides: added ''Planning Pointers'' and ''Practical Checklists'' related to the tax consequences of creating, acquiring, and transferring intellectual property; new chapters on the tax treatment of intellectual property held by business entities and non-profit organizations; expanded coverage of popular tax planning strategies used in connection with IP, including new guidance on the use of domestic and international subsidiary corporations; additional discussions in ''plain English'' of transfer pricing and cost sharing arrangements; and a new chapter on estate planning for intellectual property, including special tax and non-tax considerations for IP owners. New in the 2017 Cumulative Supplement: discussion of the Protecting Americans from Tax Hikes (PATH) Act of 2015, which made permanent the research tax credit, expanded the credit so that some start-up companies and small businesses can use it to offset payroll taxes or the alternative minimum tax, made permanent the deduction for off-the-shelf software, and extended a number of other tax benefits, including the deduction for film and television productions; a summary of recent IRS guidance on the tax treatment of domain names the first guidance on domain name taxation provided by the IRS; review of recent IRS ruling addressing the deductibility of salaries of researchers; recent rulings on the tax treatment of ERP software, as well as rulings denying tax exempt status to research organizations; cases dealing with the deductibility of film production costs and the deductibility of photography expenses; discussion of a case distinguishing for tax purposes a patent sale from a patent license, and a case on the tax treatment of patent litigation costs; recent developments related to state challenges to the intellectual property holding company model, including the enactment of so-called ''add-back'' statutes and adoption of so-called ''combined reporting.''; newly updated federal and state rules for Internet taxation, including updated charts and summaries for all 50 states; and analysis of the trend toward shifting intellectual property and related income offshore to low-tax or no-tax jurisdictions, including some of the ways U.S. based multinational entities have been able to avoid many of the existing anti-deferral provisions in the Code, and some of the proposals that have been made to limit income shifting.