Patent Asset Transfers: Tax Implications of Patent Sale, License, Cost Share Arrangement, Contribution

Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. He has significant experience in advising clients to qualify for a variety of federal income tax credits. He has also been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions.

Ms. Tollis specializes in the U.S. tax aspects of cross-border transactions, both inbound and outbound. She advises a wide range of U.S. and foreign clients on tax planning for starting or expanding operations abroad or in the U.S. market, including through mergers, acquisitions, reorganizations, and joint ventures, and she advises both participants and sponsors in the global capital markets on securities offerings and tax efficient structured finance, including cross border securitizations. 

Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the U.S. He brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. He is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.