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LimeGreenIP News

Tag Archives: tax

Monetizing IP in your M&A transactions: Hong Kong-Shanghai-Beijing seminars

Our international tax, corporate and intellectual property partners will hold seminars in Hong Kong (3 Sept.), Shanghai (4 Sept.) and Beijing (5 Sept.), with lively discussion on the monetization of your intellectual property (IP) in the context of M&A transactions. While IP makes up a high percentage of Enterprise Value (if not the majority in some industries!), it

Blockchain podcast interview: “The taxman cometh” to cryptocurrency transactions

Ted Mlynar and Ira Schaefer from our Blockchain-Smart Contract IPMT Working Group return to the Fordham Intellectual Property, Media & Entertainment Law Journal podcast series following their first episode in November 2017. Ted and Ira open this podcast with a brief account of Bitcoin’s background and give an overview of the current cryptocurrency landscape. They go on to discuss the following

German tax treatment of royalties regarding software license and database licenses

– Draft guidance of German Federal Ministry of Finance released for discussion purposes Yesterday the German Federal Ministry of Finance (Bundesfinanzministerium) released a draft circular on the German tax treatment of royalties paid for software and database licenses granted by non-resident licensors (the draft can be found here). The draft is highly important to clients

BEPS – Germany on the way to limit the tax deductibility of royalties

A new legislative approach of the German tax authorities leaked last December 19 and approved by the German government on January 25, 2017 (see German language text here) will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not

U.S. – Considering the value of manufacturing trade secrets

These days, licensing between affiliate members of a multinational corporate family is prevalent. While reaching agreement between friendly parties on licensing terms may be easier than it normally would be between arms-length parties from an economic perspective, these transactions are likely to come under intense scrutiny from the relevant tax authorities worldwide. Understanding the value

Tax dispute over Coca-Cola’s non-U.S. trademarks explained

The IRS and Coca-Cola are locked in a battle regarding the proper allocation of income between Coca-Cola and its foreign affiliates pursuant to trademark and trade secret licenses. However, the IRS seems to overlook a significant economic component of the license agreement by not recognizing the benefit Coca-Cola receives in the form of more valuable